CASE LAW UPDATE: Whether the offenses of theft by swindle and theft by false representation were not the same behavioral incident?
Defendant was convicted and sentenced for convictions of one (1) count of theft by swindle and five (5) counts of theft by false representation. On appeal, defendant argued that the trial court erred when it treated several of the convictions as separate offense instead of part of the same behavioral incident. The Minnesota Court of Appeals concluded that the convictions did not arise our of the same behavioral incident, noting that they involved claims that defendant submitted on behalf of a personal care provider organization in 2013, 2014, and 2015. Affirmed.
State v. Williams, A19-1352, Hennepin County.
Minneapolis Criminal Defense Lawyer Lynne Torgerson was not attorney of record in this case.