Florida Statute 812.131 - Full Text and Legal Analysis

The 2025 Florida Statutes

Title XLVI
CRIMES

Chapter 812
THEFT, ROBBERY, AND RELATED CRIMES

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F.S. 812.131

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.

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Amendments to 812.131

Annotations, Discussions, Cases:

Arrestable Offenses / Crimes under Fla. Stat. 812.131

Level: Degree
Misdemeanor/Felony: First/Second/Third

S812.131 2a - ROBBERY - BY SUDDEN SNATCHING W FIREARM OR WEAPON - F: S

S812.131 2b - ROBBERY - BY SUDDEN SNATCHING WO FIREARM OR WEAPON - F: T

Cases Citing Statute 812.131

Total Results: 40

United States v. Lockley

632 F.3d 1238, 2011 U.S. App. LEXIS 2781, 2011 WL 476875

Court of Appeals for the Eleventh Circuit | Filed: Feb 11, 2011 | Docket: 1888895

Cited 153 times | Published

from its less-serious counterpart, Fla. Stat. § 812.131(1), which concerns "robbery by sudden snatching

United States v. Derwin Fritts

841 F.3d 937, 2016 U.S. App. LEXIS 20172, 2016 WL 6599553

Court of Appeals for the Eleventh Circuit | Filed: Nov 8, 2016 | Docket: 4486635

Cited 115 times | Published

1999, Florida enacted a wholly separate statute, § 812.131, which proscribes sudden snatching. See 1999 Fla

State v. Burris

875 So. 2d 408, 2004 WL 742099

Supreme Court of Florida | Filed: Apr 8, 2004 | Docket: 1684026

Cited 58 times | Published

victims. In 2001, the Florida Legislature passed section 812.131, Florida Statutes (2001) (robbery by sudden

In Re Standard Jury Instructions in Criminal Cases—Report No. 2008-08

6 So. 3d 574, 34 Fla. L. Weekly Supp. 232, 2009 Fla. LEXIS 313, 2009 WL 465938

Supreme Court of Florida | Filed: Feb 26, 2009 | Docket: 1665876

Cited 34 times | Published

adopted in 2009. 15.4 ROBBERY BY SUDDEN SNATCHING § 812.131, Fla. Stat. To prove the crime of Robbery by Sudden

Brown v. State

848 So. 2d 361, 2003 WL 1877417

District Court of Appeal of Florida | Filed: Apr 16, 2003 | Docket: 2516162

Cited 14 times | Published

of the robbery by sudden snatching statute, section 812.131(1) ("from the victim's person"), does not require

Clark v. State

43 So. 3d 814, 2010 Fla. App. LEXIS 12384, 2010 WL 3326161

District Court of Appeal of Florida | Filed: Aug 25, 2010 | Docket: 2396962

Cited 6 times | Published

snatching,” the third-degree felony proscribed by section 812.131, Florida Statutes (2008). In connection with

Smith v. State

891 So. 2d 1133, 2005 WL 53241

District Court of Appeal of Florida | Filed: Jan 12, 2005 | Docket: 452255

Cited 5 times | Published

while robbery by sudden snatching does not. § 812.131(1). Brown v. State, 848 So.2d 361 (Fla. 4th DCA

State v. Floyd

872 So. 2d 445, 2004 WL 1073419

District Court of Appeal of Florida | Filed: May 14, 2004 | Docket: 1356823

Cited 5 times | Published

purse because she had possession of Floyd. Section 812.131(1), Florida Statutes (2002), defines robbery

Burris v. State

825 So. 2d 1034, 2002 WL 31039623

District Court of Appeal of Florida | Filed: Sep 13, 2002 | Docket: 1312312

Cited 5 times | Published

[1] § 812.13(2)(c), Fla. Stat. (2001). [2] § 812.131, Fla. Stat. (2001). [3] In Nation, Judge Ervin

Owens v. State

787 So. 2d 143, 2001 WL 427616

District Court of Appeal of Florida | Filed: Apr 27, 2001 | Docket: 1744983

Cited 5 times | Published

abolished this requirement when it enacted section 812.131, Florida Statutes (1999), "Robbery by sudden

United States v. Isaac Seabrooks

839 F.3d 1326, 2016 WL 6090860

Court of Appeals for the Eleventh Circuit | Filed: Oct 19, 2016 | Docket: 4480450

Cited 4 times | Published

enactment of Fla. Stat. § 812.131, a “robbery by sudden snatching” statute. Section 812.131 says that a person

Simmons v. State

780 So. 2d 263, 2000 WL 33188170

District Court of Appeal of Florida | Filed: Feb 28, 2001 | Docket: 1298849

Cited 4 times | Published

703 So.2d 1045, 1047 (Fla.1997). Although section 812.131, Florida Statutes, the section under which

In re: Steven Jackson

826 F.3d 1343, 2016 U.S. App. LEXIS 11672, 2016 WL 3457659

Court of Appeals for the Eleventh Circuit | Filed: Jun 24, 2016 | Docket: 3082732

Cited 3 times | Published

statute. Id. at 1311 & n. 30; see also Fla. Stat. § 812.131. Lockley analyzed this later *1347

Connolly, Jr. v. State

172 So. 3d 893, 2015 Fla. App. LEXIS 11352

District Court of Appeal of Florida | Filed: Jul 29, 2015 | Docket: 2679137

Cited 3 times | Published

or in fleeing after the attempt or commission. § 812.131 (3)(a), Fla. Stat. (2015). An act shall be deemed

JW v. Leitner

801 So. 2d 295, 2001 WL 1589616

District Court of Appeal of Florida | Filed: Dec 14, 2001 | Docket: 1744731

Cited 3 times | Published

because he was charged with a violation of section 812.131(2)(b), Florida Statutes (2001), robbery by

Adams v. State

122 So. 3d 976, 2013 WL 5576095, 2013 Fla. App. LEXIS 16224

District Court of Appeal of Florida | Filed: Oct 11, 2013 | Docket: 60234832

Cited 2 times | Published

sudden snatching, a third-degree felony. See § 812.131, Fla. Stat. (2011). Allegedly, Adams attacked

Wess v. State

67 So. 3d 1133, 2011 Fla. App. LEXIS 11853, 2011 WL 3198822

District Court of Appeal of Florida | Filed: Jul 28, 2011 | Docket: 2362535

Cited 2 times | Published

of robbery by sudden snatching pursuant to section 812.131, Florida Statutes. Appellant contends the trial

Thomas v. State

933 So. 2d 45, 2006 WL 1329691

District Court of Appeal of Florida | Filed: Jul 12, 2006 | Docket: 1711933

Cited 2 times | Published

Thomas of robbery by snatching in violation of section 812.131(1), Florida Statutes (2002), and fleeing and

Nichols v. State

927 So. 2d 90, 2006 WL 908441

District Court of Appeal of Florida | Filed: Apr 11, 2006 | Docket: 1764940

Cited 2 times | Published

sudden snatching" as that offense is defined by section 812.131(1), Florida Statutes (2004). Because the appellant

Cohen v. State

920 So. 2d 682, 2006 WL 141485

District Court of Appeal of Florida | Filed: Jan 20, 2006 | Docket: 2543891

Cited 2 times | Published

robbery by sudden snatching in violation of section 812.131(1), Florida Statutes (2002). The trial court

TN v. State

896 So. 2d 878, 2005 WL 473983

District Court of Appeal of Florida | Filed: Mar 2, 2005 | Docket: 1683623

Cited 2 times | Published

by sudden snatching, which is prohibited by section 812.131, Florida Statutes (2003). The trial court placed

C.A. v. State

255 So. 3d 520

District Court of Appeal of Florida | Filed: Oct 10, 2018 | Docket: 64689260

Cited 1 times | Published

of the money or other property' ") (quoting section 812.131, Fla. Stat. (2014) and Fla. Std. J. Inst. (Crim

A.M. v. State

147 So. 3d 98, 2014 Fla. App. LEXIS 12145, 2014 WL 3456157

District Court of Appeal of Florida | Filed: Aug 6, 2014 | Docket: 60243431

Cited 1 times | Published

1 In 1999, the Florida Legislature enacted section 812.131, Florida Statutes, entitled “Robbery by Sudden

Gregory Welch v. United States

Court of Appeals for the Eleventh Circuit | Filed: May 6, 2020 | Docket: 17132246

Published

“Robbery by Sudden Snatching” statute, Fla. Stat. § 812.131, which explicitly details the amount of force

C.A. v. State

District Court of Appeal of Florida | Filed: Oct 10, 2018 | Docket: 8015415

Published

of the money or other property’”) (quoting section 812.131, Fla. Stat. (2014) and Fla. Std. J. Inst. (Crim

Douglas v. State

239 So. 3d 157

District Court of Appeal of Florida | Filed: Feb 7, 2018 | Docket: 6297809

Published

see § 812.131(1)(a), Fla. Stat. (2010), or that the victim offered any resistance, see § 812.131(1)(b)

K.S., a child v. State of Florida

186 So. 3d 41, 2016 Fla. App. LEXIS 2287

District Court of Appeal of Florida | Filed: Feb 17, 2016 | Docket: 3036654

Published

“from the victim’s person” in violation of section 812.131(1), Florida Statutes (2014). Appellant

O.A. v. State

146 So. 3d 135, 2014 Fla. App. LEXIS 13685, 2014 WL 4344546

District Court of Appeal of Florida | Filed: Sep 3, 2014 | Docket: 60242848

Published

felonies: (i) robbery by sudden snatching (section 812.131, Florida Statutes (2014)), and, (ii) possession

O.A. v. State

District Court of Appeal of Florida | Filed: Sep 3, 2014 | Docket: 1150414

Published

felonies: (i) robbery by sudden snatching (section 812.131, Florida Statutes (2014)), and, (ii) possession

A.M. v. State

District Court of Appeal of Florida | Filed: Aug 6, 2014 | Docket: 762121

Published

In 1999, the Florida Legislature enacted section 812.131, Florida Statutes, entitled “Robbery by Sudden

A.M. v. State

District Court of Appeal of Florida | Filed: Jul 16, 2014 | Docket: 433705

Published

In 1999, the Florida Legislature enacted section 812.131, Florida Statutes, entitled “Robbery by Sudden

Lafferty v. State

114 So. 3d 1115, 2013 WL 2661819, 2013 Fla. App. LEXIS 9439

District Court of Appeal of Florida | Filed: Jun 14, 2013 | Docket: 60231759

Published

occurred on June 6, 2011, in violation of section 812.131(2)(b). The vic*1117tim is the same victim listed

United States v. Gregory Welch

683 F.3d 1304, 2012 WL 2122163

Court of Appeals for the Eleventh Circuit | Filed: Jun 13, 2012 | Docket: 876770

Published

was injuiy to the victim’s person.” Fla. Stat. § 812.131 (2000). 31 . Robinson v

United States v. Theodore D. Lockley

Court of Appeals for the Eleventh Circuit | Filed: Feb 11, 2011 | Docket: 2906579

Published

from its less-serious counterpart, Fla. Stat. § 812.131(1), which concerns “robbery by sudden snatching

McCollum v. State

950 So. 2d 1285, 2007 Fla. App. LEXIS 4303, 2007 WL 858620

District Court of Appeal of Florida | Filed: Mar 23, 2007 | Docket: 64849664

Published

REVERSED. TORPY and LAWSON, JJ., concur. . § 812.131(2)(b), Fla. Stat. (2005). . There was a place

Walker v. State

933 So. 2d 1236, 2006 Fla. App. LEXIS 12005, 2006 WL 1999439

District Court of Appeal of Florida | Filed: Jul 19, 2006 | Docket: 64845783

Published

that the court improperly denied the motion. Section 812.131(1), Florida Statutes (2000), defines robbery

Scott v. State

898 So. 2d 1213, 2005 Fla. App. LEXIS 5433, 2005 WL 901179

District Court of Appeal of Florida | Filed: Apr 20, 2005 | Docket: 64837488

Published

sudden snatching, a third degree felony. See § 812.131, Fla. Stat. (2001). We agree. Where a third degree

T.N. v. State

896 So. 2d 878, 2005 Fla. App. LEXIS 2453

District Court of Appeal of Florida | Filed: Mar 2, 2005 | Docket: 64836888

Published

sudden snatching, which is. prohibited by section 812.131, Florida Statutes (2003). The trial court placed

Sanders v. State

769 So. 2d 506, 2000 Fla. App. LEXIS 13664, 2000 WL 1545025

District Court of Appeal of Florida | Filed: Oct 20, 2000 | Docket: 64801096

Published

THOMPSON, C.J., and COBB, J., concur. . See § 812.131, Fla. Slat. (1999); Ch. 99-175, § 1, Laws of Fla

Haydon v. State

755 So. 2d 785, 2000 Fla. App. LEXIS 4421, 2000 WL 378156

District Court of Appeal of Florida | Filed: Apr 14, 2000 | Docket: 64796780

Published

legislature has now made it clear, by the passage of section 812.131, Florida Statutes, (robbery by sudden snatching)