State v. Peters

After being arrested for shoplifting, Pamela Peters (defendant) gave police a false name (her husband's ex-wife's name) and used that identity to seek bail, successfully getting it reduced based on the false identity's clean record and stable address; the deception was quickly discovered, and once Peters's true, more serious criminal history came out, bail was increased and the state amended the charges to add identity theft. The trial court granted Peters's motion to dismiss the identity-theft charge, reasoning the statute's "anything else of value" language, under the doctrine of ejusdem generis, was limited to items of commercial value and didn't cover bail. The State appealed, and the court of appeals certified the question.