P. v. Alvarez CA4/3
After visiting a store fitting room, Ryan Alvarez turned shoplifting into a conviction for second degree robbery by choking a Kohl’s store loss prevention officer who chased him down after he left the store with various items of clothing (socks, boxers and another pair of pants) stuffed into his trousers. This sort of escalation of crimes from what would ordinarily be a misdemeanor into a felony is commonly referred to among lawyers specializing in criminal law as an “Estes robbery,” after People v. Estes (1983) 147 Cal.App.3d 23 (Estes ). That court held Estes committed a robbery because he used force to prevent a “guard from retaking the property and to facilitate his escape.” (Id. at p. 28.)
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