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State v. Bellavia

Citations: 599 So. 2d 915; 1992 La. App. LEXIS 1760; 1992 WL 112088Docket: No. 91-KA-1488

Court: Louisiana Court of Appeal; May 28, 1992; Louisiana; State Appellate Court

Narrative Opinion Summary

In this case, a defendant was convicted of attempted issuing of a worthless check after he delivered a check for $4,275.00 to an oyster supplier, despite having insufficient funds to cover it. The transaction occurred under LSA-R.S. 14:71(A), which defines 'issuing' as delivering a check with the intent to defraud, irrespective of its completeness. The supplier inserted the final amount on the check post delivery, and the check subsequently bounced. The defendant did not rectify the bounced check within the stipulated ten-day notice period. The defendant contested that the check was not properly 'issued' due to its initial incompleteness. However, the court clarified that the legal definition of 'issue' under the statute does not necessitate that the check be completed in form at the time of delivery. The jury was found to have sufficient evidence to determine that an issuance with intent to defraud had occurred. Consequently, the court upheld the conviction and sentence, underscoring the jury's role in interpreting the defendant's actions under the statute.

Legal Issues Addressed

Definition of 'Issuing' a Check under LSA-R.S. 14:71(A)

Application: The court applied the statute's broad definition of 'issuing' to determine that the delivery of a check with intent to defraud constitutes issuance, regardless of whether the check is complete in form.

Reasoning: The statute defines 'issuing' as delivering a check with intent to defraud, regardless of whether it is 'complete in form.'

Role of the Jury in Determining Issuance under Fraudulent Check Statutes

Application: The court emphasized the jury's role in evaluating whether the defendant's actions met the statutory definition of 'issuance' under fraud statutes.

Reasoning: The court affirmed the conviction and sentence, emphasizing that it was the jury's role to determine if the defendant's actions constituted an 'issuance' under the statute.

Sufficiency of Evidence for Intent to Defraud

Application: The court found that the jury had sufficient evidence to conclude that the defendant issued the check with intent to defraud, despite the check lacking a completed amount at the time of delivery.

Reasoning: The jury found sufficient evidence to establish that an issuance occurred.