United States v. Gallant

2010 DNH 070
CourtDistrict Court, D. New Hampshire
DecidedApril 16, 2010
Docket09-CR-177-SM
StatusPublished

This text of 2010 DNH 070 (United States v. Gallant) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Gallant, 2010 DNH 070 (D.N.H. 2010).

Opinion

United States v . Gallant 09-CR-177-SM 04/16/10 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America

v. Criminal N o . 09-cr-177-1-SM Opinion N o . 2010 DNH 070 Robert Gallant

O R D E R

A grand jury returned an eleven-count superseding indictment

against Robert Gallant on January 2 0 , 2010, charging him with six

counts of false representation of a social security number, in

violation of 42 U.S.C. § 408(a)(7)(B) (Counts I , III, IV, V , VII,

and VIII); four counts of aggravated identity theft, in violation

of 18 U.S.C. § 1028A(a)(1) (Counts I I , V I , IX, and X I ) ; and one

count of bank fraud, in violation of 18 U.S.C. § 1344 (Count X ) .

Gallant moves to dismiss Counts I I , V I , IX, X , and X I . The

government objects.

Background

The superseding indictment charges that Gallant falsely

presented a social security number to the New Hampshire

Department of Motor Vehicles as his own (Count I ) , and, in

relation to that crime, he also unlawfully used someone else’s

identity — their name, date of birth, and social security number

(with two of the numerals reversed) (Count I I ) . Similarly, Counts III, IV, and V allege, respectively, that Gallant falsely

presented a social security number as his own to the Gilmanton,

Loudon, and Manchester, New Hampshire, police departments. Count

VI alleges that, in relation to those crimes, Gallant unlawfully

used someone else’s identity — their name, date of birth, place

of birth, and social security number (with two of the numerals

reversed). Following this pattern, Counts VII and VIII allege

that defendant falsely represented a social security number as

his own t o , respectively, the Concord District Court and a local

bail commissioner, and the Rochester District Court and a local

bail commissioner. Count IX alleges that, in relation to Counts

VII and VIII, Gallant unlawfully used someone else’s identity —

their name, date of birth, and social security number (with two

of the numerals reversed).

Count X alleges that Gallant defrauded TD Bank by using

someone else’s identity — their name, date of birth, and social

security number (with two numerals reversed) to open and then

overdraw a checking account. Count XI alleges that, in relation

to Count X , Gallant used someone else’s identity — their name,

date of birth, social security number (with two numerals

reversed), and a fraudulently obtained New Hampshire driver’s

license bearing someone else’s name and date of birth.

2 It is undisputed for purposes of this motion that defendant

used the name, date of birth, and place of birth of Robert Gordon

Mann, who was born on February 2 2 , 1964, in S t . Louis, Missouri.

Robert Mann’s social security number is XXX-XX-9048, while the

social security number defendant used was XXX-XX-0948. The

social security number ending in -0948 was actually issued to one

Mabel Parker, who is now deceased.

Standard of Review

A motion to dismiss counts of an indictment tests the

sufficiency of those counts to charge an offense. See United

States v . Sampson, 371 U.S. 7 5 , 79 (1962); United States v . Bohai

Trading Co., Inc.. 45 F.3d 577, 578 n.1 (1st Cir. 1995); United

States v . Thompson, 595 F. Supp. 2d 143, 145 (D. M e . 2009).

“[A]n indictment is sufficient if i t , first, contains the

elements of the offense charged and fairly informs a defendant of

the charge against which he must defend, and, second, enables him

to plead an acquittal or conviction in bar of future prosecutions

for the same offense.” Hamling v . United States, 418 U.S. 8 7 ,

117 (1974); United States v . Ditomasso, 552 F. Supp. 2d 233, 238

(D.R.I. 2008) (“The issue in judging the sufficiency of the

indictment is whether the indictment adequately alleges the

elements of the offense and fairly informs the defendant of the

charge, not whether the Government can prove its case.”)

3 (quotation marks omitted). Because a challenge to the indictment

does not test the government’s case, “[c]ourts should . . . avoid

considering evidence outside the indictment when testing the

indictment’s legal sufficiency.” United States v . Todd, 446 F.3d

1062, 1067 (10th Cir. 2006). In ruling on a motion to dismiss

counts of an indictment, the factual allegations of those counts

are taken as true. Boyce Motor Lines, Inc. v . United States, 342

U.S. 337, 343 n.16 (1952); Bohai Trading Co., 45 F.3d at 578 n.1.

Discussion

A. “Means of Identification” in Counts I I , V I , IX, and XI

Gallant moves to dismiss Counts I I , V I , IX, and X I , on

grounds that those counts do not adequately allege the use of a

“means of identification” as defined by 18 U.S.C. § 1028(d)(7).

Specifically, Gallant argues that the indictment does not

describe the crime of aggravated identity theft, because while it

alleges that defendant used three non-unique identifiers (name,

date of birth, and place of birth) that belonged to a single real

person, it also specifically alleges that he used a unique

identifier (social security number) that did not belong to that

person, but to a completely different person. Gallant says the

information used must be viewed as a whole — and that, as pled,

the identifiers used do not, as a matter of law, identify a

4 “specific individual,” as required by § 1028(d)(7). 1 In essence,

Gallant argues that the indictment does not allege a violation of

§ 1028A because it describes the identity of a fictional

composite person’s identity, not that of a real person.

The government objects contending that the indictment

adequately charges that Gallant used Robert Mann’s full name and

date of birth (and, in Count V I , his place of birth), which is

sufficient to avoid dismissal of the aggravated identity theft

charges. The government also argues that it is for a jury to

decide whether use of the name, date, and place of birth, and a

substantially similar (and, inferentially, manipulated) social

security number, is sufficient to constitute the theft of Robert

Mann’s identity.

An indictment, or counts of an indictment, generally are not

dismissed based on insufficient evidence. See, e.g., Costello v .

United States, 350 U.S. 359, 408-09 (1956). This is so because

such action risks usurping the role of the grand jury, and would

inevitably result in delay, because a defendant “could always

insist on a kind of preliminary trial to determine the competency

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Related

United States v. Bonilla
579 F.3d 1233 (Eleventh Circuit, 2009)
Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Boyce Motor Lines, Inc. v. United States
342 U.S. 337 (Supreme Court, 1952)
Costello v. United States
350 U.S. 359 (Supreme Court, 1956)
Harris v. Florida Real Estate Commission
371 U.S. 7 (Supreme Court, 1962)
Ashe v. Swenson
397 U.S. 436 (Supreme Court, 1970)
Burks v. United States
437 U.S. 1 (Supreme Court, 1978)
United States v. Todd
446 F.3d 1062 (Tenth Circuit, 2006)
United States v. Bohai Trading Co.
45 F.3d 577 (First Circuit, 1995)
United States v. Jackman
48 F.3d 1 (First Circuit, 1995)
United States v. John R. Swaim
757 F.2d 1530 (Fifth Circuit, 1985)
United States v. Donald F. Ferris
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United States v. Terry Burton Kimbrough
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United States v. Donald Ray Goodine
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United States v. Benjamin Godfrey Chipps, Sr.
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United States v. Sabri Yakou
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United States v. Mitchell
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United States v. Ditomasso
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