This section contains the nature of the case and procedural background.

Moses (D) was a practitioner of the 'Jamaican Switch.' D approached a victim and took on a foreign accent when he asked directions to a hotel. D's accomplice then approached him and offered to show him the way. D told the victim he did not trust the accomplice. D then asked the victim to keep a large amount of his money for him. D asked the victim to put his own money in a handkerchief along with D's money, to ensure good faith, and then lock it in the trunk of the victim's car. D switched the handkerchiefs and disappeared with the victim's money. D was convicted under an Arizona statute for obtaining money through a scheme to defraud. D appealed; the statute codifies common law false pretenses, and the victim did not intend to pass title to the money.

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