State v. Bedoni
In State v. Bedoni, 161 Ariz. 480, 482-83, 779 P.2d 355, 357-58 (App. 1989), the Court considered whether the use of a false signature on a traffic citation was sufficient evidence of the defendant's intent to defraud. 161 Ariz. at 482-84, 779 P.2d at 357-59.
In that case, an officer gave the defendant a citation during a traffic stop for driving without a license. Id. at 482, 779 P.2d at 357.
The defendant signed the citation on the "'promise to appear' portion of the ticket" using a false name. Id. The defendant was charged with and convicted of forgery. Id.
On appeal, the Court first noted that a "promise to appear by a fictitious person is meaningless." Id. at 484, 779 P.2d at 359.
The false signature "deceived the officer and the court system, not to mention risked trouble for some unknown person" bearing the same name. Id.
In addition, the defendant would gain a benefit because "it conceals the true identity of the perpetrator of the alleged crime and seeks to obtain the release, without incarceration, of someone not entitled to release." Id. The Court concluded that "all of these acts could be found by a jury to constitute an 'intent to defraud.'" See id.