N.J. Stat. » Title 2C — THE NEW JERSEY CODE OF CRIMINAL JUSTICE
New Jersey Statutes

N.J. Stat. § 2C:20-4 (2026)

Theft by deception

✓ current as of May 2026
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2C:20-4. Theft by deception.

A person is guilty of theft if he purposely obtains property of another by deception. A person deceives if he purposely:

a. Creates or reinforces a false impression, including false impressions as to law, value, intention or other state of mind, and including, but not limited to, a false impression that the person is soliciting or collecting funds for a charitable purpose; but deception as to a person's intention to perform a promise shall not be inferred from the fact alone that he did not subsequently perform the promise;

b. Prevents another from acquiring information which would affect his judgment of a transaction; or

c. Fails to correct a false impression which the deceiver previously created or reinforced, or which the deceiver knows to be influencing another to whom he stands in a fiduciary or confidential relationship.

The term "deceive" does not, however, include falsity as to matters having no pecuniary significance, or puffing or exaggeration by statements unlikely to deceive ordinary persons in the group addressed.

Notes of Decisions
Cited in 104 cases (44 in the last 5 years), 1972–2026 · leading case: State v. Bernardi, 192 A.3d 1040 (N.J. Super. Ct. App. Div. 2018).
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State v. Bernardi, 192 A.3d 1040 (N.J. Super. Ct. App. Div. 2018). · cites it 13× “2C:21-34(b) (count one); second-degree theft by deception from the NJDEP, N.J.S.A. 2C:20-4(a) (count two); first-degree financial facilitation of criminal activity, N.”
Jan Knapik v. John Ashcroft, Attorney Gen. of the United States, 384 F.3d 84 (3d Cir. 2004). “3d at 226 (citing N.J. Stat. Ann. § 2C:20-4). Nonetheless, both Nugent and Munroe found it proper to examine the amount of loss established.”
State of New Jersey Vs. John C. Van Ness (13-01-0208, Monmouth Cnty. & Statewide), 163 A.3d 911 (N.J. Super. Ct. App. Div. 2017). · cites it 2× “Van Ness on three counts of third degree theft by deception, N.J.S.A. 2C:20-4 (counts one, five, and nine); three counts of fourth degree passing a check knowing it will not be honored, N.”
Munroe v. Ashcroft, 353 F.3d 225 (3d Cir. 2003). · cites it 2× “1228-07-95) charged Munroe with one count of theft by deception, in violation of N.J.S.A. 2C:20-4, and alleged that Munroe had unlawfully obtained $1,000 from the First Fidelity Bank in Union City, New Jersey, in August 1994, by depositing bad checks and then withdrawing $1,000…”
Germaine Music v. Universal Songs of Polygram, 275 F. Supp. 2d 1288 (D. Nev. 2003). · cites it 2× “250 (2003), N.J. Stat. § 2C:20-4 (2003), Or.Rev.Stat.”
Commodity Futures Trading Comm'n v. Am. Metals Exch. Corp., 775 F. Supp. 767 (D.N.J. 1991). · cites it 3× “2C:20-9 & 2C:2-7, and second degree theft by deception under N.J.S.A. 2C:20-4 & 2C:2-7. In pertinent part, N.”
State v. Talley, 466 A.2d 78 (N.J. 1983). “He was convicted of theft by deception, N.J.S.A. 2C:20-4 1 . The grand jury had received no evidence of *388 deception, and deception is not a necessary ingredient of a robbery conviction.”
Kwok Sum Wong v. Garland, 95 F.4th 82 (2d Cir. 2024). · cites it 2× “Wong’s predicate offenses were theft by deception in violation of N.J. Stat. Ann. § 2C:20-4 and second-degree forgery in violation of N.”
State v. Rodgers, 554 A.2d 866 (N.J. Super. Ct. App. Div. 1989). · cites it 2× “II: Commentary (1971) § 2C:20-4 at 224; hereinafter Final Report, Vol.”
Barry v. Santander Bank, N.A. (In re Liberty State Benefits of Delaware, Inc.), 541 B.R. 219 (Bankr. D. Del. 2015). · cites it 2× “Predicate Act IX: Theft by Deception Santander further asserts that the Complaint fails to plead a claim for Theft by Deception under N.J.S.A. § 2C:20-4. The Court concurs with Santander’s contention.”
State v. Thyfault, 297 A.2d 873 (N.J. Super. Ct. App. Div. 1972). · cites it 2× “State, supra , in its Penal Code, § 2C:20-4. The commentary indicates, "We follow the decisions that impose liability whenever a defendant obtains property by a knowing misstatement of the law.”
State v. Gorman, 185 A.3d 902 (N.J. Super. Ct. App. Div. 2018). · cites it 2× “*345 Defendant John Gorman appeals from an order denying his motion to withdraw a guilty plea he entered to second-degree theft by deception, N.J.S.A. 2C:20-4, 1 arguing: POINT I THERE WAS AN INADEQUATE FACTUAL BASIS FOR THE CRIME OF THEFT BY DECEPTION, THEREFORE DEFENDANT'S…”
Show all 104 citing cases →
N.J. Stat. § 2C:20-4(8)(c): 1 case
State v. Thyfault, 297 A.2d 873 (N.J. Super. Ct. App. Div. 1972). “State, supra , in its Penal Code, § 2C:20-4. The commentary indicates, "We follow the decisions that impose liability whenever a defendant obtains property by a knowing misstatement of the law.”
N.J. Stat. § 2C:20-4(a): 28 cases
State v. Bernardi, 192 A.3d 1040 (N.J. Super. Ct. App. Div. 2018). “2C:21-34(b) (count one); second-degree theft by deception from the NJDEP, N.J.S.A. 2C:20-4(a) (count two); first-degree financial facilitation of criminal activity, N.”
State of New Jersey Vs. Richard W. Bernardi, Sr. (16-02-0014, Morris Cnty. & Statewide) (record Impounded), No. A-0752-17T3 (N.J. Super. Ct. App. Div. Aug. 28, 2018).
State of New Jersey v. Wilson A. Pinos Rivera, No. A-3253-21 (N.J. Super. Ct. App. Div. Mar. 4, 2024).
State of New Jersey Vs. Irving Fryar (13-10-0197, Burlington Cnty. & Statewide), No. A-3700-15T4 (N.J. Super. Ct. App. Div. June 27, 2018).
State of New Jersey Vs. Yvonne Jeannotte-rodriguez State of New Jersey Vs. Marta I. Galvan State of New Jersey Vs. Lisa Ferraro (19-06-0446, Passaic Cnty. & Statewide) (Consol.), No. A-4361-19/A-4371-19/A-4374-19 (N.J. Super. Ct. App. Div. Aug. 25, 2021).
N.J. Stat. § 2C:20-4(b): 1 case
State of New Jersey Vs. Michelle Rosales-serrano(15-02-0424, Essex Cnty. & Statewide), No. A-2684-15T4 (N.J. Super. Ct. App. Div. June 12, 2017).
N.J. Stat. § 2C:20-4(c): 2 cases
Barry v. Santander Bank, N.A. (In re Liberty State Benefits of Delaware, Inc.), 541 B.R. 219 (Bankr. D. Del. 2015). “Predicate Act IX: Theft by Deception Santander further asserts that the Complaint fails to plead a claim for Theft by Deception under N.J.S.A. § 2C:20-4. The Court concurs with Santander’s contention.”
State of New Jersey Vs. Frances M. Wise (15-01-0004, Warren Cnty. & Statewide), No. A-4992-16T4 (N.J. Super. Ct. App. Div. Dec. 21, 2018).
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