People v. Bochenek

Defendant was convicted, after jury trial, of identity theft for the knowingly unauthorized use of another person's credit card information to purchase cigarettes. The venue provision pertaining to identify theft, which allows for proper venue in the county in which the victim resides, is constitutional. A victim's possessory interest in his or her personal identifying information is located where the victim resides. The part of the offense that involves misappropriation of the personal information can be said to be committed in the county where the victim lives because the information is said to be "located" there. (A. BURKE, GARMAN, NEVILLE, OVERSTREET, and CARTER.)