Florida Statutes

Fla. Stat. § 812.131 (2025)

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.

(2)(a) If, in the course of committing a robbery by sudden snatching, the offender carried a firearm or other deadly weapon, the robbery by sudden snatching is a felony of the second degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.

(b) If, in the course of committing a robbery by sudden snatching, the offender carried no firearm or other deadly weapon, the robbery by sudden snatching is a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.

(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.

Arrestable Offenses under F.S. 812.131

M = misdemeanor · F = felony · degree: F=1st S=2nd T=3rd

§812.131(2a)ROBBERYROBBERY SUDDEN SNATCHING WITH FIREARM/WEAPONF · 2nd

§812.131(2b)ROBBERYROBBERY SUDDEN SNATCH WITHOUT FIREARM/WEAPONF · 3rd

Notes of Decisions

Cited in 49 cases, 2000–2020 · leading case: United States v. Isaac Seabrooks, 839 F.3d 1326 (11th Cir. 2016).

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United States v. Isaac Seabrooks, 839 F.3d 1326 (11th Cir. 2016). · cites it 5× “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, 43 So. 3d 814 (Fla. 1st DCA 2010). · cites it 12× “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, 848 So. 2d 361 (Fla. 4th DCA 2003). · cites it 7× “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, 139 S. Ct. 544 (2019). “" Fla. Stat. § 812.131 (1999). Thus, the application of the categorical approach to the Florida robbery statute is straightforward.”

United States v. Lockley, 632 F.3d 1238 (11th Cir. 2011). · cites it 2× “13(1) from its less-serious counterpart, Fla. Stat. § 812.131 (1), which concerns “robbery by sudden snatching.”

State v. Burris, 875 So. 2d 408 (Fla. 2004). · cites it 2× “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, 841 F.3d 937 (11th Cir. 2016). “- Fla. Stat. § 812.131 (1999) (emphasis added).”

Connolly, Jr. v. State, 172 So. 3d 893 (Fla. 3d DCA 2015). · cites it 3× “§ 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, 684 F. App'x 870 (11th Cir. 2017). · cites it 2× “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, 651 F. App'x 920 (11th Cir. 2016). · cites it 2× “See Fla. Stat. § 812.131 ; 1999 Fla. Laws 969 ; see also Lockley, 632 F.”

State v. Smith, 23 So. 3d 291 (La. 2009). · cites it 2× “" Fla. Stat. Ann. § 812.131 (1)(West 2000); see Brown v.”

In re: Steven Jackson, 826 F.3d 1343 (11th Cir. 2016). “30; see also Fla. Stat. § 812.131 . Lockley analyzed this later *1347 scheme and held that this new version of § 812.”

Show all 49 citing cases →

— 812.131(1) — 12 cases

Clark v. State, 43 So. 3d 814 (Fla. 1st DCA 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, 848 So. 2d 361 (Fla. 4th DCA 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, 933 So. 2d 45 (Fla. 4th DCA 2006).

Nichols v. State, 927 So. 2d 90 (Fla. 1st DCA 2006).

Cohen v. State, 920 So. 2d 682 (Fla. 2d DCA 2006).

— 812.131(1)(a) — 2 cases

Brown v. State, 848 So. 2d 361 (Fla. 4th DCA 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, 239 So. 3d 157 (Fla. 3d DCA 2018).

— 812.131(1)(b) — 1 case

Douglas v. State, 239 So. 3d 157 (Fla. 3d DCA 2018).

— 812.131(2) — 2 cases

T.N. v. State, 896 So. 2d 878 (Fla. 2d DCA 2005).

TN v. State, 896 So. 2d 878 (Fla. 2d DCA 2005).

— 812.131(2)(b) — 6 cases

JW v. Leitner, 801 So. 2d 295 (Fla. 2d DCA 2001).

T.N. v. State, 896 So. 2d 878 (Fla. 2d DCA 2005).

Lafferty v. State, 114 So. 3d 1115 (Fla. 2d DCA 2013).

TN v. State, 896 So. 2d 878 (Fla. 2d DCA 2005).

— 812.131(3)(a) — 1 case

Connolly, Jr. v. State, 172 So. 3d 893 (Fla. 3d DCA 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, 848 So. 2d 361 (Fla. 4th DCA 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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