Arizona Revised Statutes

Ariz. Rev. Stat. § 13-1901 (2026)

Definitions

✓ current as of May 2026
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In this chapter, unless the context otherwise requires:

1. "Force" means any physical act directed against a person as a means of gaining control of property.

2. "In the course of committing" includes any of the defendant's acts beginning with the initiation and extending through the flight from a robbery.

3. "Property of another" means property of another as defined in section 13-1801.

4. "Threat" means a verbal or physical menace of imminent physical injury to a person.

Notes of Decisions
Cited in 32 cases (4 in the last 5 years), 1966–2026 · leading case: State v. Roque, 141 P.3d 368 (Ariz. 2006).
State v. Roque, 141 P.3d 368 (Ariz. 2006). · cites it 8× “” A.R.S. § 13-1901(1). ¶ 83 In California, “[r]obbery is the felonious taking of personal property in the possession of another, from his person or immediate presence, and against his will, accomplished by means of force or fear.”
State v. Yarbrough, 638 P.2d 737 (Ariz. Ct. App. 1981). · cites it 10× “rough, on or about the 6th day of April, 1980, in the course of taking property of another from Shar-lette MacDougall’s person or immediate presence and against her will, used threats or force against Sharlette Mac-Dougall, with the intent to coerce surrender of the property or…”
State v. Owens, 20 S.W.3d 634 (Tenn. 2000). · cites it 6× “Ann. tit. 17-A, § 651 (West 1983); Minn. Stat.”
State v. Hyde, 921 P.2d 655 (Ariz. 1996). · cites it 4× “The original complaint charged defendant with robbery under A.R.S. §§ 13-1901, -701, -702, -801, and -812.”
State v. McNair, 687 P.2d 1230 (Ariz. 1984). · cites it 4× “, was convicted and adjudged guilty of armed robbery, a Class 2 felony, in violation of A.R.S. §§ 13-1901, -1902, -1904, 13-301, -302, -303, and 13-604.”
United States v. Rogelio Sanchez Molinar, 881 F.3d 1064 (9th Cir. 2017). · cites it 4× “” Ariz. Rev. Stat. § 13-1902 (A). The statute defines “force” as “any physical act directed against a person as a means of gaining control of property.”
State of Arizona v. Daniel Andrew Snider, 311 P.3d 656 (Ariz. Ct. App. 2013). · cites it 4× “§ 13-1901(4), and “‘[f]orce’ means any physical act directed against a person as a means of gaining control of property,” A.R.S. § 13-1901(1). ¶ 10 The state presented substantial evidence from which the jury could infer that Snider had used or threatened to use force during the…”
State v. Miguel, 611 P.2d 125 (Ariz. Ct. App. 1980). · cites it 4× “The charges against Miguel were: Count I, robbery of Gustavo Freeman while armed with a deadly weapon, to wit: a gun and a knife, a class 2 felony, in violation of A.R.S. §§ 13-1901, 13-1902, 13-1904, 13-604, 13-701, 13-801; * Count II, robbery of Michael McKinnon while armed…”
State v. Linden, 664 P.2d 673 (Ariz. Ct. App. 1983). · cites it 4× “See, Comments, Criminal Code Commission [1975] to A.R.S. § 13-1901 (“[Existing Robbery Offenses] replaced by a tripartite division covering certain aggravating factors between simple and armed robbery.”
State v. Stevens, 909 P.2d 478 (Ariz. Ct. App. 1995). · cites it 6× “A.R.S. § 13-1901. Threat means “a verbal or physical menace of imminent physical injury to a person.”
State v. Garza Rodriguez, 791 P.2d 633 (Ariz. 1990). · cites it 2× “A.R.S. §§ 13-1901(4) and -1902(A); see Bishop, 144 Ariz.”
State v. Tresize, 623 P.2d 1 (Ariz. 1980). · cites it 2× “JACK LOUIS TRESIZE’S taking or retaining the property while an accomplice was armed with a deadly weapon or used or threatened to use a deadly weapon or dangerous instrument, a pistol, in violation of A.R.S. § 13-1901, 13-1902, 13-1904, 13-701, 13-702 and 13-801.”
— Ariz. Rev. Stat. § 13-1901(1) — 5 cases
State v. Roque, 141 P.3d 368 (Ariz. 2006). “” A.R.S. § 13-1901(1). ¶ 83 In California, “[r]obbery is the felonious taking of personal property in the possession of another, from his person or immediate presence, and against his will, accomplished by means of force or fear.”
State v. Yarbrough, 638 P.2d 737 (Ariz. Ct. App. 1981). “rough, on or about the 6th day of April, 1980, in the course of taking property of another from Shar-lette MacDougall’s person or immediate presence and against her will, used threats or force against Sharlette Mac-Dougall, with the intent to coerce surrender of the property or…”
State of Arizona v. Daniel Andrew Snider, 311 P.3d 656 (Ariz. Ct. App. 2013). “§ 13-1901(4), and “‘[f]orce’ means any physical act directed against a person as a means of gaining control of property,” A.R.S. § 13-1901(1). ¶ 10 The state presented substantial evidence from which the jury could infer that Snider had used or threatened to use force during the…”
State v. Moore (Ariz. Ct. App. 2014).
State v. Godoy (Ariz. Ct. App. 2022).
— Ariz. Rev. Stat. § 13-1901(2) — 5 cases
State v. Lopez, 762 P.2d 545 (Ariz. 1988).
State v. Linden, 664 P.2d 673 (Ariz. Ct. App. 1983). “See, Comments, Criminal Code Commission [1975] to A.R.S. § 13-1901 (“[Existing Robbery Offenses] replaced by a tripartite division covering certain aggravating factors between simple and armed robbery.”
United States v. Garcia-Caraveo, 586 F.3d 1230 (10th Cir. 2009).
State v. Jones (Ariz. Ct. App. 2024).
State v. Garcia (Ariz. Ct. App. 2015).
— Ariz. Rev. Stat. § 13-1901(4) — 7 cases
State v. Roque, 141 P.3d 368 (Ariz. 2006). “” A.R.S. § 13-1901(1). ¶ 83 In California, “[r]obbery is the felonious taking of personal property in the possession of another, from his person or immediate presence, and against his will, accomplished by means of force or fear.”
State v. Garza Rodriguez, 791 P.2d 633 (Ariz. 1990). “A.R.S. §§ 13-1901(4) and -1902(A); see Bishop, 144 Ariz.”
State v. Yarbrough, 638 P.2d 737 (Ariz. Ct. App. 1981). “rough, on or about the 6th day of April, 1980, in the course of taking property of another from Shar-lette MacDougall’s person or immediate presence and against her will, used threats or force against Sharlette Mac-Dougall, with the intent to coerce surrender of the property or…”
State of Arizona v. Daniel Andrew Snider, 311 P.3d 656 (Ariz. Ct. App. 2013). “§ 13-1901(4), and “‘[f]orce’ means any physical act directed against a person as a means of gaining control of property,” A.R.S. § 13-1901(1). ¶ 10 The state presented substantial evidence from which the jury could infer that Snider had used or threatened to use force during the…”
State v. Stevens, 909 P.2d 478 (Ariz. Ct. App. 1995). “A.R.S. § 13-1901. Threat means “a verbal or physical menace of imminent physical injury to a person.”
— Ariz. Rev. Stat. § 13-1901(A) — 1 case
Cordova v. Shinn (D. Ariz. 2021).
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