The court of appeals recently decided that an indictment alleging that a defendant stole some shirts from “Belk’s Department Stores, an entity capable of owning property,” did not sufficiently identify the victim as an entity capable of owning property. State v. Brawley, __ N.C. App. __, __ S.E.2d __, 2017 WL 4632820 (Oct. 17, 2017). This post summarizes the decision, considers the possibility of further review, and explains how other states handle this issue.