United States v. Amanda Komp ( 2023 )

United States Court of Appeals
For the Eighth Circuit
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No. 22-3198
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United States of America,
Plaintiff Appellee,
v.
Amanda Renee Komp,
Defendant Appellant.
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No. 22-3222
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United States of America,
Plaintiff Appellee,
v.
Tammy McCullough,
Defendant Appellant.
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Appeals from United States District Court
for the Western District of Arkansas - Ft. Smith
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Submitted: February 13, 2023
Filed: February 16, 2023
[Unpublished]
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Before COLLOTON, BENTON, and GRASZ, Circuit Judges.
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PER CURIAM.
In these consolidated appeals, Amanda Komp and Tammy McCullough appeal
after they were found guilty by a jury of fraud offenses. They argue that the district
court1 erred in denying their motions for judgment of acquittal as to the offense of
aggravated identity theft, asserting that a signature does not constitute a “means of
identification” under 18 U.S.C. §§ 1028(d)(7) and 1028A. We conclude that the
district court did not err, because a forged signature constitutes a “means of
identification” under the applicable provisions. See United States v. Porter, 745 F.3d
1035, 1042 (10th Cir. 2014); United States v. Blixt, 548 F.3d 882, 886 (9th Cir. 2008).
Accordingly, we affirm.
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1
The Honorable P.K. Holmes, III, United States District Judge for the Western
District of Arkansas.
-2-