People v. DeBates

A Boone County grand jury indicted Defendant on 8 counts of forgery, alleging that he knowingly delivered to the State Board of Elections a Congress Primary Petition containing a fraudulent signature of  Boone County residents. Court properly dismissed the indictment on the ground of improper venue, finding no evidence that the named residents suffered any detriment due to the forgery. There is no statutory provision identifying, as the "victim" of forgery, the person whose name is forged. The State may not designate someone as a victim where the elements of the offense do not otherwise require it, merely to establish venue in a particular county. (McLAREN and JORGENSEN, concurring.)