State v. Baker (1974)

Cf. United States v. Fekri, 650 F.2d 1044 (9th Cir.1981) (defendant is deemed to have notice even if the indictment cites the wrong statute; the statement of facts in the indictment rather than statutory citations should control); State v. Baker, 55 Hawaii 621 , 525 P.2d 571, 572 (1974) (indictment that contained technical error in wording did not prejudice defendant; under Hawaii law, offense may be charged either by name or by reference to the statute defining it).

Cf. State v. Baker, 55 Haw. 621, 622-23 , 525 P.2d 571, 572 (1974) (holding that the indictment charging defendant with forgery in the second degree was sufficient, although inarticulately drawn due to technical errors in its wording, because it " provided the [defendant] with sufficient facts to put him on reasonable notice of the charges against him ") (emphasis added).

Stat. § 18-5-102 (2004) (instrument evidencing or creating legal obligation includes check); Conn. Gen.Stat. § 53a-139 (1976) (referenced in State v. Henderson, 47 Conn. App. 542 , 706 A.2d 480, 485 (1998), implicitly noting commercial instrument includes check; forging check is felony of lesser degree); Del.Code Ann. tit. 11, § 861 (1995) (instrument evidencing or creating legal obligation includes check; forging check is felony of lesser degree); Haw.Rev.Stat. § 708-852 (1…

See State v. Baker, 55 Haw. 621, 622-23 , 525 P.2d 571, 572 (1974) (indictment charging defendant with forgery in the second degree was sufficient, although inarticulately drawn due to technical errors in its wording, because it “provided the [defendant] with sufficient facts to put him on reasonable notice of the charges against him”); Sprattling, 99 Hawai'i at 315, 331 , 55 P.3d at 279, 295 (Levinson, J. and Ramil, J., dissenting) (in assault ease, oral charge alleged that…