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Wash. Court of Appeals published opinion — D2 51946-1-II Published Opinion.pdf

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Wash. Court of Appeals published opinion — D2 51946-1-II Published Opinion.pdf
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Washington (state)
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contained a piece of false information. He contends that merely providing false information in

this context cannot be the basis for a forgery charge.

But Mark is distinguishable because Smith did not simply provide false information when

completing the applications. He also provided the social security number of another person, a

child in Indiana. The court in Mark specified that “[a] misrepresentation of fact, so long as it

does not purport to be the act of someone other than the maker, does not constitute forgery.” 94

Wn.2d at 523. And RCW 9A.60.010(4) states that to falsely complete a written instrument

means to complete it “by adding or inserting matter, without the authority of anyone entitled to

grant it.” (Emphasis added). A social security number is a form of identification, and Smith’s

use of the Indiana child’s social security number misrepresented that someone with that social

security number was opening a bank account. Smith also did not have the authority to use the

social security number of the child in Indiana.1