Commonwealth v. Begun

After a trial, a jury convicted the defendant of violating G. L. c. 267, § 1,2 for submitting a falsified bill of sale to his employer, the town of Shirley, for reimbursement. On appeal, both the defendant and the Commonwealth agree that count 1 of the complaint was defective for failing to allege sufficient facts that would constitute a violation of G. L. c. 267, § 1. To sustain a conviction under G. L. c. 267, § 1, the Commonwealth must prove that the defendant "with intent to injure or defraud, falsely ma[de], alter[ed], forge[d] or counterfeit[ed]" one of the instruments enumerated…