State v. Jones, 367 N.C. 299

Jones was stopped for a suspected card-theft case; he could not produce license or registration.
A search yielded a Maaco work order under James Coleman and marijuana in Jones's vehicle.
Wallet items included credit-card numbers for Rini, Payton, Daly, and Batchelor; all such individuals stayed at The Blake Hotel in May 2010 with White listed as payment contact.
White admitted writing down several customers' identifying information and providing it to another person; unauthorized charges followed on some cards.
Indictments charged Jones with four counts of trafficking in stolen identities, two counts of obtaining property by false pretenses, and one count of identity theft; White was charged with four counts of trafficking in stolen identities.
At trial, the court dismissed the false pretenses charges and White trafficking charges as fatally defective; the identity theft charge against Jones proceeded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of identity theft mens rea	Jones possessed others' numbers with fraudulent intent to represent himself as them.	No proof Jones intended to represent that he was the named individuals.	Identity theft sufficient evidence of intent found; denial of dismissal affirmed.
Sufficiency of indictments for obtaining property by false pretenses	Indictment language of 'services' described the property obtained with precision.	Describing as 'services' is too vague to allege the offense.	Indictments insufficient; trial court affirmed dismissal.
Sufficiency of indictments for trafficking in stolen identities (Jones)	Recipient identity not required by statute; identifying information itself suffices.	Common-law requirement to name recipient or show unknown recipient applies.	Indictments insufficient; remanded/affirmed dismissal.
Sufficiency of indictments for trafficking in stolen identities (White)	Indictment language mirrors statute and identifies victims, dates, and items.	Bissette rule applies; must name recipient or unknown recipient.	Indictments insufficient under common-law rule; trial court properly dismissed.

State v. Hunt, 365 N.C. 432 (2012) (substantial-evidence standard for motion to dismiss)
State v. Abshire, 363 N.C. 322 (2009) (substantial-evidence standard; elements of offenses)
State v. Worsley, 336 N.C. 268 (1994) (indictment sufficiency and §15A-924(a)(5) framework)
State v. Palmer, 293 N.C. 633 (1977) (indictment sufficiency—language of statute generally sufficient)
State v. Cronin, 299 N.C. 229 (1980) (indictment specificity and supplemental allegations)
State v. Cook, 272 N.C. 728 (1968) (supplementing statutory language to charge elements)
State v. Bissette, 250 N.C. 514 (1959) (recipient-name requirement for certain offenses)
State v. Tisdale, 145 N.C. 305 (1907) (reasoning for identifying the recipient in fungible goods cases)
State v. Bennett, 280 N.C. 167 (1971) (extension of Bissette rule to narcotics offenses)
State v. Sturdivant, 304 N.C. 293 (1981) (double jeopardy and indictment purposes)
Nelson v. Freeland, 349 N.C. 615 (1998) (courts' discretion to abandon obsolete rules)
Freeman, 314 N.C. 432 (1985) (indictments liberal construction; aims of §15A-924)
State v. Rowland, 263 N.C. 353 (1965) (elements of offense and notice to defendant)