NC · jury_instructions
N.C.P.I.—Crim. 219B.80B
IDENTITY THEFT-POSSESSION OF IDENTIFYING INFORMATION PERTAINING TO THREE OR MORE PERSONS. FELONY.
The defendant has been charged with possession of identifying
information pertaining to three or more persons.
For you to find the defendant guilty of this offense, the State must
prove three things beyond a reasonable doubt.
First, that the defendant [obtained] [possessed] [used] personal
identifying information1 of another person. (Name type of identifying
information, e.g., social security number) would be personal identifying
information.
Second, that the defendant acted knowingly and with the intent2 to
fraudulently represent that the defendant was that other person for the
purpose of [making [financial] [credit] transactions in the other person's
name] [obtaining anything of [value] [benefit] [advantage]] [avoiding
legal consequences].
And Third, that the defendant was in possession of the identifying
information pertaining to three or more persons.
NOTE WELL: Until December of 2002, lack of consent
of the victim was an element of the offense.
If you find from the evidence beyond a reasonable doubt that on or
about the alleged date the defendant [obtained] [possessed] [used]
personal identifying information of another person, that the defendant did
so knowingly, with the intent to fraudulently represent that the defendant
was that other person for the purpose of [making [financial] [credit]
transactions in the other person's name] [obtaining anything of [value]
[benefit] [advantage]] [avoiding legal consequences], and that the
defendant was in possession of the identifying information of three or
more persons, it would be your duty to return a verdict of guilty. If you do
not so find or have a reasonable doubt as to one or more of these things,
then you will consider whether the defendant is guilty of identity theft.
Identity theft differs from possession of the identifying information of
three or more persons in that the state is not required to prove that the
defendant was in possession of the identifying information of three or
more persons.
If you find from the evidence beyond a reasonable doubt that on or
about the alleged date the defendant [obtained] [possessed] [used]
personal identifying information of another person, that the defendant did
so knowingly, and with the intent to fraudulently represent that the
defendant was that other person for the purpose of [making [financial]
[credit] transactions in that other person's name] [obtaining anything of
[value] [benefit] [advantage]] [avoiding legal consequences], it would be
your duty to return a verdict of guilty of identity theft. If you do not so
find or have a reasonable doubt as to one or more of these things, it
would be your duty to return a verdict of not guilty.
History
N.C.P.I.—Crim. 219B.80B (June 2010). N.C. Gen. Stat. §§ 14-113.20; 14-113.22. Prepared by the North Carolina Conference of Superior Court Judges' Committee on Pattern Jury Instructions, assisted by the UNC School of Government; published by the School of Government.
Provenance
- Source
- sog.unc.edu
- Retrieved
- 2026-09-24
- Edition
- 2026-09-24
- Content hash
498e92f48b3d4c99343364b11ffb8f403e8f1428b3065fcc266d1810cd8105c7
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