Parks v. State

Ebony Janae Parks v. State of Maryland, No. 1096, September Term, 2022. Opinion by Ripken, J. CRIMINAL LAW – IDENTITY FRAUD – VALUE IS AN ELEMENT Value is an element of the identity fraud offenses proscribed by Maryland Code, Criminal Law Article (“CR”), section 8-301. The maximum penalty to which a defendant may be exposed for a violation of CR section 8-301(b) depends, according to CR section 8-301(g), upon proof of the value of the “benefit, credit, good, service, or other thing . . . that is the subject of subsection (b)[.]” CR section 8-301 is not meaningfully distinguishable from the…