Ark. Code Ann. § 5-12-101 (2026)

Case Notes

Physical Force.

Evidence held sufficient to show that defendant employed physical force against the victim, inasmuch as there was sufficient restraint and bodily impact to constitute physical force. Fairchild v. State, 269 Ark. 273, 600 S.W.2d 16 (1980).

Evidence sufficient to find that the force exerted was sufficient to accomplish its purpose. Turner v. State, 270 Ark. 969, 606 S.W.2d 762 (1980).

Testimony by store employees that they ran after and tackled defendant after seeing him take an item from the store without paying for it implied that some type of physical force was used against them, even if one of the employees was the person who used physical force first, and was sufficient to prove the use of physical force element. Payne v. State, 86 Ark. App. 59, 159 S.W.3d 804 (2004).

For purposes of this section, it was immaterial whether defendant ever intended to use physical force against the victim to further his escape; physical force meant any bodily impact, and the testimony from the victim was that defendant struck him in the nose, which was corroborated by a police officer and believed by the jury. McElyea v. State, 87 Ark. App. 103, 189 S.W.3d 67 (2004), aff'd, 360 Ark. 229, 200 S.W.3d 881 (2005).

Defendant used physical force to get away from a store employee who had caught him shoplifting and told him that a report needed to be filed where defendant struck the employee when the employee grabbed his sleeve. McElyea v. State, 360 Ark. 229, 200 S.W.3d 881 (2005).

Court rejected defendant's argument that the evidence was insufficient to support his conviction of felony robbery under § 5-12-102(a) because the state failed to prove that he used physical force to take the victim's purse where the state presented no evidence of a struggle or fight, of more force than necessary to pull the purse from the victim's arm, or of his touching any part of the victim's body. Because the victim testified that defendant snatched her purse from her, causing pain and bruises to her hand and right arm, the jury could have inferred from this evidence that injury was done, that force was used in taking the purse, and that bodily impact occurred sufficient to meet the statutory requirement of physical force. Banks v. State, 2009 Ark. App. 633 (2009).

Evidence was sufficient to support defendant's robbery conviction, given that he pulled up to the victim in a car and asked if he could use the victim's phone, and when the victim refused, defendant punched him in the face, took the phone, and drove away; the victim positively identified defendant, who handed the phone over to the officers, and the circuit court was free to believe the testimony of the victim and not that of defendant, who claimed he was just borrowing the phone. Muhammad v. State, 2016 Ark. App. 285, 494 S.W.3d 440 (2016).

Evidence was sufficient to sustain defendant's robbery conviction where an undercover security guard testified that defendant placed a bottle of laundry detergent inside her flat purse, the purse bulged, defendant did not pay for the detergent before walking out of the store, she shoved the guard when he confronted her in the parking lot, and she fled the scene abruptly when confronted by loss-prevention officers. Horton v. State, 2017 Ark. App. 481, 530 S.W.3d 880 (2017).

Cited: Tippitt v. Lockhart, 859 F.2d 595 (8th Cir. 1988); Baldwin v. State, 48 Ark. App. 181, 892 S.W.2d 534 (1995); Boyd v. State, 54 Ark. App. 17, 922 S.W.2d 357 (1996); Cartwright v. State, 2016 Ark. App. 425, 501 S.W.3d 849 (2016).