State v. Rodriguez

In State v. Rodriguez, Cuyahoga App. No. 89198, 2007 Ohio 6835, Rodriguez was charged with 17 counts of tampering with records for allegedly using a fake social security card to obtain titles to motor vehicles. He contended that the statute of limitations had run on some of the counts. The Court agreed, finding that "the 17 counts of the indictment related to 17 different applications for a title to a motor vehicle. All 17 of these applications used the same fraudulent social security number. These 17 offenses were distinct, and each was completed when Rodriguez made the application for a title." Id. at P25. (See Kilbane, J., dissenting, finding a continuing course of conduct.)