P. v. Wilson CA4/2
Defendant and appellant Athena Wilson shoplifted clothing from a Target store but used no force or fear until she punched, scratched, and bit a security officer who approached her after her exit. A jury convicted her of robbery pursuant to Penal Code section 211, which requires the crime be “accomplished by means of force or fear.” In People v. Estes (1983) 147 Cal.App.3d 23, 28 (Estes), the Court of Appeal held that the requisite force need not occur contemporaneously with the taking of goods from a store, but instead could occur to prevent a guard from retaking the property or to facilitate the defendant’s escape.
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