What Court Records Reveal About Counterfeit IDs and Identity Fraud
The problem is bigger than a counterfeit card — but the evidence is narrower than the headlines suggest
In North Dakota, the phrase fake ID can describe several different forms of conduct: presenting a fictitious driver's license, using a genuine document issued to another person, or supplying someone else's personal information to obtain employment or financial benefits.
The distinction is not merely semantic. It determines which law may apply, what evidence investigators need, and whether a case actually says anything about counterfeit identification in the workplace.
A federal case announced in Bismarck on October 20, 2026, illustrates the issue. According to the U.S. Attorney's Office for the District of North Dakota, Linford Atakora used a relative's name, date of birth, and Social Security number to obtain employment at Love & Care, Inc., a home health agency. Prosecutors said he presented the relative's driver's license and Social Security card and completed employment-related paperwork under that identity.
The government reported that the misrepresentations were associated with $51,435.63 in ineligible health and human services units and claims. Atakora was sentenced to approximately nine months in federal custody, with credit for time served, and received an order of removal to Ghana.
Source: U.S. Attorney's Office, District of North Dakota.
This case documents employment-related identity misuse. It does not establish that Atakora used a counterfeit North Dakota driver's license. The government described the use of a relative's identity and documents, not the manufacture of a fake card.
That qualification matters because a genuine document can be misused by someone other than its rightful holder. A system that checks only whether a card appears authentic may not resolve the separate question of who is presenting it.
The central finding of this investigation is therefore precise: North Dakota has documented cases involving fictitious credentials and identity misuse, but the public records reviewed here do not establish a reliable statewide rate of counterfeit IDs used to obtain employment.
1. Five cases that show why the categories must remain separate
The following cases were identified through searches of published North Dakota Supreme Court decisions and federal prosecution announcements. They are not a complete count of every relevant incident in the state.
IDENTITY-RELATED CASES
|
+--------------------+---------------------+
| | |
▼ ▼ ▼
Fictitious ID Identity misuse Other fraud
| | |
▼ ▼ ▼
Richter, Atakora, 2026 Lee, 2022
Lanctot McKee, 2022 (stolen mail)
|
▼
Boynton, 2026
(false-name license;
separate charge issue)
The cases differ in conduct, outcome, and relevance to employment.
+---------------------------+----------------------------------+-----------------------+
| Case | Conduct documented | Relevance |
+---------------------------+----------------------------------+-----------------------+
| State v. Lanctot | Two fictitious IDs | State license law |
| 1998 ND 216 | found in a wallet | |
+---------------------------+----------------------------------+-----------------------+
| Patrick McKee | Long-term use of | Identity misuse |
| Federal sentence | another person's | including |
| 2022 | identity | employment |
+---------------------------+----------------------------------+-----------------------+
| State v. Richter | Counterfeit | Fictitious license |
| 2023 ND 221 | Minnesota license | under ND law |
+---------------------------+----------------------------------+-----------------------+
| State v. Boynton | Fictitious license | Limits of a specific |
| 2026 ND 120 | with false name | criminal charge |
+---------------------------+----------------------------------+-----------------------+
| Linford Atakora | Relative's identity | Employment- |
| Federal sentence | used to obtain work |-related identity |
| 2026 | | misuse |
+---------------------------+----------------------------------+-----------------------+
Case 1: State v. Lanctot — two fictitious licenses
In State v. Lanctot, 1998 ND 216, police found two fictitious driver's licenses in Douglas Lanctot's wallet after arresting him at an auto-repair business in West Fargo.
Lanctot challenged the warrantless search of his wallet. The North Dakota Supreme Court affirmed the conviction, concluding the search was lawful under the circumstances described in the opinion.
Source: State v. Lanctot, 1998 ND 216.
The case is relevant to North Dakota's history of enforcing laws against fictitious licenses. But the Supreme Court's central issue was the legality of the search, not the prevalence of fake IDs in employment.
The opinion also does not establish that the two licenses were used to secure work.
Case 2: Patrick McKee — a stolen identity used for years
In January 2022, federal prosecutors announced the sentencing of Patrick Robert McKee, also known as William Patrick O'Hara, for offenses including aggravated identity theft, false statements, and health care fraud.
According to the prosecution announcement, McKee stole another person's identity in 1997 and then lived and worked under that identity. The government said he used it to obtain healthcare benefits, mortgages, credit cards, and other benefits or services.
He received a two-year federal prison sentence and three years of supervised release.
Source: U.S. Attorney's Office, District of North Dakota — McKee sentencing.
This case is important because it illustrates the potential duration and breadth of identity misuse. It does not, however, establish that a counterfeit driver's license was used in the employment process. It should be classified as a stolen-identity case, not automatically counted as a fake-ID hiring case.
Case 3: State v. Richter — a counterfeit license and a clear statutory rule
In State v. Richter, 2023 ND 221, Eli Richter was convicted after displaying a counterfeit Minnesota driver's license to a police officer in Grand Forks.
Richter argued that the card could not qualify as an operator's license because no state had issued it. The North Dakota Supreme Court rejected that interpretation. It held that the statutory reference to a “fictitious” operator's license covers a counterfeit credential.
The court affirmed the order deferring imposition of sentence.
Source: State v. Richter, 2023 ND 221.
This is a direct counterfeit-license case. It supports a legal conclusion about the display of a fictitious license under North Dakota law. It does not establish how frequently counterfeit credentials are used in hiring.
Case 4: State v. Boynton — a false document does not prove every element of every charge
In State v. Boynton, 2026 ND 120, Dreashun Maurice Boynton presented a driver's license bearing a false name during a law-enforcement encounter in Stark County.
He pleaded guilty to providing false information to a law-enforcement officer. The North Dakota Supreme Court reversed the judgment and remanded the case to allow him to withdraw his guilty plea because the record did not establish the materiality element required for that particular offense.
Source: State v. Boynton, 2026 ND 120.
The decision did not make fictitious driver's licenses lawful. The opinion discussed the separate statute that prohibits displaying a fictitious license and explained why the factual basis was insufficient for the specific false-information charge.
This is a crucial distinction for any investigation: the existence of a fictitious document and the legal sufficiency of a particular criminal charge are different questions.
Case 5: Linford Atakora — employment under a relative's identity
The 2026 Bismarck case is the most directly relevant employment example among the cases reviewed here.
The prosecution announcement says Atakora used a relative's identifying information and presented that relative's driver's license and Social Security card when applying for work. The government reported $51,435.63 in associated ineligible claims and units.
The case shows that employment-related identity misuse can have consequences beyond the hiring decision, particularly where employment is connected to public-benefit services.
It does not prove that the employer knowingly accepted fraudulent information, that its verification process was deficient, or that a counterfeit North Dakota ID was involved.
Those are separate questions that would require additional evidence.
2. What the cases establish — and what they do not
The five cases provide evidence of different types of conduct. They cannot responsibly be added together to produce a statewide fake-ID statistic.
+----------------------------------------+------------------------------------+
| Research question | Finding from reviewed cases |
+----------------------------------------+------------------------------------+
| Have fictitious licenses been | Yes |
| involved in ND court cases? | |
+----------------------------------------+------------------------------------+
| Has identity misuse affected | Yes |
| employment in North Dakota? | |
+----------------------------------------+------------------------------------+
| Has a counterfeit ND license | Not established by the |
| been proven in every case? | cases summarized here |
+----------------------------------------+------------------------------------+
| Do these cases establish a | No |
| statewide prevalence rate? | |
+----------------------------------------+------------------------------------+
| Do they prove employers | No |
| generally fail verification? | |
+----------------------------------------+------------------------------------+
A court case is evidence that a particular matter reached a particular stage of the justice system. It is not a complete count of all incidents. Some conduct may go undetected, be handled under different laws, or never result in a published appellate opinion.
The opposite mistake is also possible: several documented cases do not establish that fake-ID fraud is widespread.
The reviewed sources do not provide a reliable statewide figure for:
the number of employers that encountered counterfeit IDs during hiring;
the annual number of applications involving another person's identity;
the rate of change in these incidents;
the industries most affected;
the total annual financial loss attributable to counterfeit identification in hiring;
the proportion of document discrepancies that turn out to be legitimate administrative problems.
Any article claiming those numbers would need additional records or a systematic dataset.
3. Independent expert analysis: where verification systems can fail
The public cases establish specific events. To understand the wider verification problem, they need to be considered alongside independent policy analysis.
In a November 2025 article for the Migration Policy Institute, researchers Muzaffar Chishti and Colleen Putzel-Kavanaugh examined the strengths and limitations of employment verification in the United States.
Their analysis argues that E-Verify can compare information submitted by employers with government records but cannot always establish that the person presenting a document is the person to whom it was issued. The authors also discuss false mismatches caused by record errors, name changes, and other discrepancies.
This is independent published commentary, not a direct interview for this article, and it is national rather than North Dakota-specific.
Its relevance is nevertheless clear. The Atakora case involved another person's identity and documents. The MPI analysis identifies a broader limitation in verification systems: a database match and a determination that the presenter is the rightful document holder are not necessarily the same thing.
That does not mean E-Verify is useless or that it would necessarily have failed in Atakora's case. The public announcement does not describe enough of the employer's verification process to make that determination.
A mismatch is not automatically proof of fraud
Federal guidance also warns against treating every data mismatch as proof that a worker is unauthorized.
The Department of Homeland Security's E-Verify guidance explains that a tentative nonconfirmation can result from incorrect data entry, a name change, outdated records, or other discrepancies. The system's mismatch process allows the employee to take steps to resolve the issue.
Source: E-Verify — DHS and SSA Mismatches.
The implication for employers is two-sided:
A genuine-looking document does not conclusively establish that the presenter is the rightful holder.
A mismatch does not conclusively establish that the worker committed fraud.
A reliable process must investigate the discrepancy without assuming either conclusion prematurely.
4. What North Dakota law says about fake IDs
North Dakota Century Code § 39-06-40 addresses unlawful use of an operator's license or nondriver photo identification card. It covers specified conduct including displaying a cancelled, revoked, fictitious, or fraudulently altered credential and displaying another person's credential as one's own.
The provision classifies the specified offense as a Class B misdemeanor. The statute also addresses certain fraudulent statements or omissions in applications for licenses and identification cards.
Official source: North Dakota Century Code, Chapter 39-06.
Chapter 12.1-24 addresses forgery and counterfeiting, while Chapter 12.1-23 addresses theft and related offenses, including specified unauthorized uses of personal identifying information.
Official sources:
The precise charge depends on the conduct and the elements of the relevant statute. A counterfeit document, another person's genuine ID, and a false statement made during an employment process are not automatically the same offense.
The legal framework in practice
IDENTIFICATION INCIDENT
|
▼
What actually happened?
|
+---------------------------+-------------------------+
| | |
▼ ▼ ▼
Fake or altered Another person's Incorrect or
credential genuine document mismatched data
| | |
▼ ▼ ▼
Examine the Establish whose Check records,
document and identity was used context and
its use possible errors
| | |
+---------------------------+-------------------------+
|
▼
Apply the relevant law
to the proven facts
The diagram is a research framework, not a substitute for legal advice or an official investigative procedure. Its purpose is to show why an incident must be classified before conclusions are drawn.
5. Employment verification: the rules employers must follow
Employers generally must complete Form I-9 to verify the identity and employment authorization of new employees.
Under U.S. Citizenship and Immigration Services guidance, workers choose which acceptable documents to present from the applicable lists. Employers generally may not insist on a particular document when an employee can provide another acceptable option.
Source: USCIS — Examining Documents for Form I-9.
The Department of Justice also explains that employers must apply Form I-9 and E-Verify procedures consistently, without discrimination based on citizenship, immigration status, or national origin.
Source: DOJ Civil Rights Division — Form I-9 and E-Verify.
A driver's license can be relevant when a job requires driving. It does not automatically establish employment authorization, and it is not universally required for every job.
Employers should distinguish four separate questions:
+-------------------------------------+-------------------------------------+
| Question | What it addresses |
+-------------------------------------+-------------------------------------+
| Is the document genuine? | Document authenticity |
+-------------------------------------+-------------------------------------+
| Does it belong to the | Identity of the presenter |
| person presenting it? | |
+-------------------------------------+-------------------------------------+
| Is employment eligibility | Applicable federal hiring |
| properly verified? | requirements |
+-------------------------------------+-------------------------------------+
| Is a valid driver's | Job-specific driving |
| license required? | qualification |
+-------------------------------------+-------------------------------------+
These checks can overlap, but none should be treated as a universal substitute for the others.
A sound process should allow legitimate discrepancies to be resolved and should avoid treating an unfamiliar document, a spelling variation, or a lost card as automatic proof of wrongdoing.
6. Fake ID websites and “scannable” claims: search demand is not evidence
Queries such as “fake ID shop,” “fake ID website,” “fake DL seller,” “fake driver's license website,” “order fake ID,” and “fake ID online” indicate that people search for these products.
They do not establish the number of active vendors, the reliability of a seller's claims, or the prevalence of counterfeit IDs in North Dakota.
The same limitation applies to phrases such as “scannable fake ID seller,” “scannable fake ID website,” and “scannable fake driver's license.”
A card's ability to produce a readable electronic response does not establish that a government authority issued it or that it belongs to the person presenting it.
Likewise, anonymous reviews, promotional claims, and discussions on forums such as Reddit should not be treated as verified evidence of a seller's performance or of criminal prevalence.
This investigation does not endorse counterfeit-ID vendors or link to sellers. The relevant questions are whether a particular incident can be documented, what kind of credential was involved, how it was used, and what the resulting investigation established.
For SEO, the practical distinction is important: a page can address the phrase “Fake ID North Dakota” without implying that search demand proves a statewide epidemic.
7. Lost or damaged North Dakota identification: the official alternative
A lost or damaged driver's license is an administrative problem, not proof of fraud.
The North Dakota Department of Transportation provides official replacement options for eligible residents who have lost, had stolen, or damaged their credentials.
Source: NDDOT — Replace a Lost, Stolen, or Damaged License.
NDDOT states that eligible residents can request a duplicate license online if they know their driver's-license information. Applicants must still be North Dakota residents, and their driving privileges cannot be currently suspended, revoked, or cancelled. A person seeking an initial REAL ID must visit a driver's-license site.
The published fee for a duplicate driver's license is $8. Applicants should verify current eligibility and requirements directly with NDDOT.
For someone searching “lost North Dakota driver's license,” “lost ND driver's license,” “lost North Dakota DL,” “lost North Dakota state ID,” or “lost ND ID,” the official state replacement process is the appropriate starting point.
If an ID was stolen and personal information may also have been exposed, the North Dakota Attorney General's identity-theft guidance is available here: Identity Theft — North Dakota Attorney General.
A legitimate replacement process should not be confused with obtaining an unofficial substitute. Keeping those situations separate protects both the integrity of identification systems and the interests of people who have genuinely lost their documents.
8. What further investigation is needed?
The public record now supports a more detailed account of fictitious licenses and identity misuse. It still does not provide a complete measure of the statewide problem.
A rigorous follow-up investigation should build a case database using published court opinions, federal prosecution announcements, and available state court records. North Dakota's official court system provides public case-search tools, although not every historical record is necessarily searchable online.
Sources:
Every case should be classified according to the conduct actually alleged or established. The database should distinguish counterfeit credentials, genuine documents used by another person, identity theft, employment-related fraud, and unrelated offenses involving personal information.
The next phase should also seek comments from independent legal experts, employment-verification specialists, employers, and relevant agencies. Their responses should be identified as interviews, written responses, or published commentary — never blended together as if they were equivalent.
A practical research plan
STEP 1 Search published court opinions
|
▼
STEP 2 Search federal and state prosecution records
|
▼
STEP 3 Classify each case by conduct and outcome
|
▼
STEP 4 Request aggregate statistics from agencies
|
▼
STEP 5 Seek independent expert and employer comments
|
▼
STEP 6 Compare the evidence and disclose data gaps
|
▼
STEP 7 Publish only claims supported by the record
This process would make it possible to answer questions that the current evidence cannot settle: whether incidents are becoming more frequent, which kinds of identity misuse are most common, and whether employers' verification practices are detecting the conduct they are designed to detect.
Conclusion: the cases are real; the statewide rate remains unknown
The cases reviewed here demonstrate that North Dakota has dealt with fictitious driver's licenses, long-term identity misuse, and employment-related identity fraud.
State v. Lanctot documents two fictitious licenses. State v. Richter confirms that displaying a fictitious license can fall within North Dakota's unlawful-use statute. State v. Boynton demonstrates that the elements of a specific criminal charge must still be established. Federal cases involving Patrick McKee and Linford Atakora show the consequences of using another person's identity, including in employment.
Independent policy analysis also identifies a limitation in employment verification: matching data to government records does not always prove that the person presenting a document is its rightful holder. Federal guidance, however, makes clear that a mismatch alone is not proof of fraud and that employers must follow nondiscrimination requirements.
These findings support a serious discussion of identity security. They do not establish a statewide fake-ID epidemic or quantify the frequency of counterfeit IDs used to obtain jobs.
The defensible conclusion is that North Dakota has documented cases of fictitious credentials and identity misuse, but the statewide prevalence of counterfeit IDs in hiring remains unquantified by the sources reviewed.
A stronger investigation will depend not on adding more search terms, but on expanding the case record, obtaining independent responses, and distinguishing proven facts from reasonable but untested hypotheses.
Sources and research method
Court cases and prosecution announcements
U.S. Attorney's Office, District of North Dakota. “Ghanaian Man Sentenced for Fraudulently Working under the Name and Social Security Number of a United States Citizen.” October 20, 2026.
https://www.justice.gov/usao-nd/pr/ghanaian-man-sentenced-fraudulently-working-under-name-and-social-security-number-unitedU.S. Attorney's Office, District of North Dakota. “United States Attorney Announces Flint, MI, Man Sentenced to Federal Prison for Aggravated Identity Theft.” January 6, 2022.
https://www.justice.gov/usao-nd/pr/united-states-attorney-announces-flint-mi-man-sentenced-federal-prison-aggravatedNorth Dakota Supreme Court. State v. Lanctot, 1998 ND 216.
https://law.justia.com/cases/north-dakota/supreme-court/1998/980218.htmlNorth Dakota Supreme Court. State v. Richter, 2023 ND 221.
https://law.justia.com/cases/north-dakota/supreme-court/2023/20230124.htmlNorth Dakota Supreme Court. State v. Boynton, 2026 ND 120.
https://law.justia.com/cases/north-dakota/supreme-court/2026/20260010.htmlU.S. Attorney's Office, District of North Dakota. “Former Dickinson, ND, Resident Sentenced to Federal Prison for Bank Fraud, Aggravated Identity Theft, and Possession of Stolen Mail.” February 24, 2022.
https://www.justice.gov/usao-nd/pr/former-dickinson-nd-resident-sentenced-federal-prison-bank-fraud-aggravated-identity
Independent published analysis and official guidance
Migration Policy Institute. Muzaffar Chishti and Colleen Putzel-Kavanaugh, “Employment Verification: The Next Front for U.S. Immigration Enforcement?” November 20, 2025.
https://www.migrationpolicy.org/journal/policy-beat/employment-verification-next-front-us-immigration-enforcementU.S. Citizenship and Immigration Services. Form I-9 acceptable-document guidance.
https://www.uscis.gov/i-9-central/form-i-9-acceptable-documents/examining-documents.htmlU.S. Department of Justice, Civil Rights Division. Form I-9 and E-Verify guidance.
https://www.justice.gov/crt/form-i-9-and-e-verifyE-Verify. DHS and SSA mismatch guidance.
https://www.e-verify.gov/employers/verification-process/tentative-nonconfirmations/dhs-and-ssa-mismatchesNorth Dakota Century Code, Chapter 39-06.
https://ndlegis.gov/cencode/t39c06.htmlNorth Dakota Century Code, Chapter 12.1-24.
https://ndlegis.gov/cencode/t12-1c24.htmlNorth Dakota Century Code, Chapter 12.1-23.
https://ndlegis.gov/cencode/t12-1c23.htmlNorth Dakota Department of Transportation. Replace a Lost, Stolen, or Damaged License.
https://www.dot.nd.gov/driver/replace-lost-stolen-or-damaged-licenseNorth Dakota Attorney General. Identity Theft.
https://attorneygeneral.nd.gov/consumer-resources/identity-theft/