812.131
Robbery by sudden snatching.
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812.131 Robbery by sudden snatching.—
(1) “Robbery by sudden snatching” means the taking of money or other property from the victim’s person, with intent to permanently or temporarily deprive the victim or the owner of the money or other property, when, in the course of the taking, the victim was or became aware of the taking. In order to satisfy this definition, it is not necessary to show that:
(a) The offender used any amount of force beyond that effort necessary to obtain possession of the money or other property; or
(b) There was any resistance offered by the victim to the offender or that there was injury to the victim’s person.
(3)(a) An act shall be deemed “in the course of committing a robbery by sudden snatching” if the act occurs in an attempt to commit robbery by sudden snatching or in fleeing after the attempt or commission.
(b) An act shall be deemed “in the course of the taking” if the act occurs prior to, contemporaneous with, or subsequent to the taking of the property and if such act and the act of taking constitute a continuous series of acts or events.
History.—s. 1, ch. 99-175.
Notes of Decisions
Cited in 49
cases, 2000–2020 · leading case: United States v. Isaac Seabrooks
United States v. Isaac Seabrooks (2016)
“In order to satisfy this definition, it is not necessary to show that: (a) The offender used any amount of force beyond that effort necessary to obtain possession of the money or other property; or (b) There was any resistance by the victim to the offender or that there was…”
Clark v. State (2010)
“But he contends he was entitled to the jury instruction defense counsel below requested on the permissive or category two lesser-included offense of "robbery by sudden snatching," the third-degree felony proscribed by section 812.”
Brown v. State (2003)
“This fact satisfies the statutory requirement of section 812.131, Florida Statutes, as it was a " continuous series of acts or events.”
Stokeling v. United States (2019)
“" Fla. Stat. § 812.131 (1999). Thus, the application of the categorical approach to the Florida robbery statute is straightforward.”
United States v. Lockley (2011)
“13(1) from its less-serious counterpart, Fla. Stat. § 812.131 (1), which concerns “robbery by sudden snatching.”
State v. Burris (2004)
“In 2001, the Florida Legislature passed section 812.131, Florida Statutes (2001) (robbery by sudden snatching), which expressly addresses the type of offense committed by Burris.”
United States v. Derwin Fritts (2016)
“- Fla. Stat. § 812.131 (1999) (emphasis added).”
Connolly, Jr. v. State (2015)
“§ 812.131 (3)(a), Fla. Stat. (2015). An act shall be deemed “in the course of committing the carjacking” if it occurs in an attempt to commit carjacking or in flight after the attempt or commission.”
United States v. Denard Stokeling (2017)
“Case: 16-12951 Date Filed: 04/06/2017 Page: 2 of 14 statute in 1999, Fla. Stat. § 812.131 , categorically qualifies as a violent felony under the elements clause of the Armed Career Criminal Act, 18 U.”
United States v. Charlie Jenkins (2016)
“See Fla. Stat. § 812.131 ; 1999 Fla. Laws 969 ; see also Lockley, 632 F.”
State v. Smith (2009)
“" Fla. Stat. Ann. § 812.131 (1)(West 2000); see Brown v.”
In re: Steven Jackson (2016)
“30; see also Fla. Stat. § 812.131 . Lockley analyzed this later *1347 scheme and held that this new version of § 812.”
— 812.131(1) — 12 cases
Clark v. State (2010)
“But he contends he was entitled to the jury instruction defense counsel below requested on the permissive or category two lesser-included offense of "robbery by sudden snatching," the third-degree felony proscribed by section 812.”
Brown v. State (2003)
“This fact satisfies the statutory requirement of section 812.131, Florida Statutes, as it was a " continuous series of acts or events.”
Thomas v. State (2006)
Nichols v. State (2006)
Cohen v. State (2006)
— 812.131(1)(a) — 2 cases
Brown v. State (2003)
“This fact satisfies the statutory requirement of section 812.131, Florida Statutes, as it was a " continuous series of acts or events.”
Douglas v. State (2018)
— 812.131(1)(b) — 1 case
Douglas v. State (2018)
— 812.131(2) — 2 cases
T.N. v. State (2005)
TN v. State (2005)
— 812.131(2)(b) — 6 cases
Clark v. State (2010)
“But he contends he was entitled to the jury instruction defense counsel below requested on the permissive or category two lesser-included offense of "robbery by sudden snatching," the third-degree felony proscribed by section 812.”
JW v. Leitner (2001)
T.N. v. State (2005)
Lafferty v. State (2013)
TN v. State (2005)
— 812.131(3)(a) — 1 case
Connolly, Jr. v. State (2015)
“§ 812.131 (3)(a), Fla. Stat. (2015). An act shall be deemed “in the course of committing the carjacking” if it occurs in an attempt to commit carjacking or in flight after the attempt or commission.”
— 812.131(3)(b) — 1 case
Brown v. State (2003)
“This fact satisfies the statutory requirement of section 812.131, Florida Statutes, as it was a " continuous series of acts or events.”
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