Colorado Court of Appeals People v. Kovacs 11CA0950

Decision here.

   I tried to keep this summary short and sweet, you may need caffeine anyway.

   Kovacs was indicted by a grand jury for forgery after he added a fictitious "Certification of Appraisal" to some appraisal paperwork that he prepared for various lenders (thankfully, that is all the information we need to discuss about what I'm sure was a riveting investigation).  He filed a motion with the district court to quash the indictment, and the indictment was quashed because the court held that adding false information to a document did not necessarily meet the elements of forgery (since it didn't transform the document into a completed or altered instrument).

   The Colorado Court of Appeals held that adding materially false information to any instrument (whether genuine or not) and thereby purporting to complete said instrument does, in fact, meet the "falsely completes" element of forgery.  In other words, someone can commit forgery by adding false information to otherwise legitimate documents with the intent to defraud.