People v. Cage
Michigan Supreme Court
410 Mich. 401 (1981)
Relevant factsFree
Cage told a car dealer he intended to buy a car pending a test drive and mechanic's inspection, but never actually intended to purchase it, planning instead to keep it for his own use, and pleaded guilty to theft by false pretenses before challenging the factual basis for that plea on appeal, with the Court of Appeals relying on a minority-rule Texas decision upholding liability based on a false statement of future intent.
IssueFree
Whether, for the crime of theft by false pretenses, the misrepresentation must relate to a present or existing fact or a past fact or event.