Nice try, Lao Che!

So here’s the story. A long time ago, one Walter Glenn Primrose stole the identity of a deceased child named Bobby Fort.

The usual thing: Primrose got himself into some financial hot water, and claimed that “someone came to his home and threatened him at gunpoint,” after which he and his wife assumed new identities. Primrose obtained baby Fort’s birth certificate, and used that to get a drivers license and a SSN. Dude even enlisted in the Coast Guard as Fort, and after separating from the service worked for the DOD as a civilian contractor.

Got a passport, including two US Government passports, and renewed his passport a few times.

It was one of those passport renewal applications where John Law finally caught up with Fort…err, Primrose. Busted:

The United States Department of State’s Fraud Prevention Office (FPO) opened an investigation into “Fort” in 2020 after his 2016 passport-renewal application was flagged as containing a late-issued Social Security Number. The FPO found the death certificate for the real Fort and referred the matter for a criminal investigation. Primrose was arrested in July 2022.

Slip op. at 6 (footnote omitted).

Primrose is prosecuted for false statements to the DOD, among other charges, and a jury convicted him. He appealed, claiming that he did not make a false statement because he is, in fact (and in law) Bobby Fort, not Walter Glenn Primrose. His argument? I adversely possessed the identity of Bobby Fort.

In United States v. Primrose aka Fort, No. 24-1462 (9th Cir. Sep. 22, 2026), the Ninth Circuit didn’t buy it.

We reject Primrose’s premise—one cannot obtain the legal right to another person’s identity simply by using it for a long time.

Slip op. at 5.

So if you are ever questioning whether one can adversely possess another’s identity (is that even “property?), here’s your citation:

As he did at trial, Primrose insists on appeal that he is not culpable for making false statements or identity theft because he had actually become Bobby Fort. Primrose concedes that “there is no criminal case which purports to authorize a defendant [to] legally assum[e] the identity of another just through the passage of time.” But he nonetheless urges us, as a matter of “fairness,” to recognize “an exception authorizing one to assume another identity when one has lived most of their adult life under that name.”

….

We appreciate Primrose’s candor in admitting that this is “a concept yet unrecognized in criminal law as it relates to assumed identities.” But we decline his invitation to develop the new law that he advocates.

There is no basis in law or reason for us to conclude that one may adversely possess the identity of another person. The Supreme Court has held that “[a]n individual’s identity is more than just his name or Social Security number.” Maryland v. King, 569 U.S. 435, 450 (2013). A person’s identity is a part of, not separate from, their personhood. And no matter how long one uses another person’s name, they simply do not become the other person.

The identities that Primrose and his wife assumed belonged to infants who were not long for this world. That the infants’ lives were short does not erase their existence or their importance. And no matter what Primrose and his wife did with the infants’ identities, those identities still belonged to the infants who were born on the dates and received the names that were recorded in their birth certificates. It is not at all clear that the infants, their parents, or family were not “harmed” by Primrose’s actions. And Primrose’s contention that he is the one “who had done the work” to establish an identity under the Bobby Edward Fort name by living a life under that name for 30 years is beside the point.

Slip op. at 7-8.

They’re gonna make a movie about this guy, aren’t they?

United States v. Primrose aka Fort, No. 24-1462 (9th Cir. Sep. 22, 2026)