Laycock v. State
Indiana Supreme Court · 1894-01-09 · cited 20×
In this case, James H. Laycock was charged under Indiana's embezzlement statute with unlawfully appropriating funds belonging to Hoosier Lodge No. 261, a fraternal association of which he was a member and served as financier or treasurer. After a jury convicted him and the trial court denied post-trial motions, Laycock appealed, arguing that the indictment was defective, the lodge was not a proper "employer" under the statute, and he could not embezzle from an entity in which he held membership interests. The court affirmed the conviction, holding that the statute covers officers or employees of associations as well as corporations or individuals, that the lodge qualified as an organized association whose dedicated funds were subject to embezzlement, and that a member's interest did not prevent criminal liability for fraudulent conversion of the association's property.