United States v. Gallant

2010 DNH 070
District Court, D. New Hampshire·Decided April 16, 2010·No. 09-CR-177-SM·Published

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.

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.”)

(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

“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

1 To the extent Gallant is arguing that these identifying characteristics, considered together, actually point to two different people, that argument addresses the potential duplicity of the superseding indictment, rather than its failure to describe a criminal offense. Duplicity is addressed below.

and adequacy of the evidence before the grand jury.” Id.; see also United States v . Pettengill, ___ F. Supp. 2d ___, 2010 WL 374437, at *1 (D. M e . Feb. 1 , 2010) (“A court should exercise its authority to dismiss cautiously, since to dismiss an indictment directly encroaches upon the fundamental role of the grand jury.”) (quotation marks omitted).

In very limited circumstances, “a court may receive evidence on a motion to dismiss.” United States v . Stevens, 578 F. Supp. 2d 172, 177 (D. M e . 2008) (citing United States v . Ferris, 807 F.2d 269, 271 (1st Cir. 1986). A district court may “dismiss charges at the pretrial stage where the operative facts are undisputed and the government fails to object to the district court’s consideration of those undisputed facts in making the determination regarding a submissible case.” Todd, 446 F.3d at 1068 (quotation marks omitted); see also United States v . Yakou, 428 F.3d 241, 247 (D.C. Cir. 2005) (collecting cases), Ferris, 807 F.2d at 271. In this instance, the operative facts appear undisputed, and the government has not objected to the court’s consideration of those facts in deciding whether to dismiss counts of the indictment.

The crime of aggravated identity-theft is described in 18 U.S.C. § 1028A(a)(1) as follows:

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

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