On June 8, 2023, the U.S. Supreme Court narrowed the reach of the aggravated identity theft statute, 18 U.S.C. § 1028A(a)(1). Criminal defense attorneys and federal prosecutors alike were anxiously awaiting the result in Dubin v. United States, 599 U.S. ____ (2023). The stakes were high. Commonly charged in mail, wire, bank, and healthcare