Ky. Rev. Stat. » Chapter 515
Kentucky Revised Statutes

Ky. Rev. Stat. § 515.020 (2026)

Robbery in the first degree

✓ current as of May 2026
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(1) A person is guilty of robbery in the first degree when, in the course of committing theft, he or she uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he or she: (a) Causes physical injury to any person who is not a participant in the crime; or (b) Is armed with a deadly weapon; or (c) Uses or threatens the immediate use of a dangerous instrument upon any person who is not a participant in the crime. (2) Robbery in the first degree is a Class B felony, unless the offense occurs during a declared emergency as defined by KRS 39A.020 arising from a natural or man- made disaster, within the area covered by the emergency declaration, and within the area impacted by the disaster, in which case it is a Class A felony. Effective: July 14, 2022 History: Amended 2022 Ky. Acts ch. 151, sec. 15, effective July 14, 2022. -- Created 1974 Ky. Acts ch. 406, sec. 130, effective January 1, 1975.

Notes of Decisions
Cited in 193 cases (34 in the last 5 years), 1976–2026 · leading case: Wilburn v. Commonwealth, 312 S.W.3d 321 (Ky. 2010).
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Wilburn v. Commonwealth, 312 S.W.3d 321 (Ky. 2010). · cites it 18× “[3] KRS 515.020 provides as follows: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical…”
Lloyd v. Commonwealth, 324 S.W.3d 384 (Ky. 2010). · cites it 20× “Robbery in the first degree, for which Lloyd was indicted and convicted, is governed by KRS 515.020, which has not been amended since first enacted in 1974.”
Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999). · cites it 12× “[2] It is unnecessary to the decision in this case to address whether double jeopardy is avoided by the fact that KRS 515.020 requires proof that the defendant acted with the intent to accomplish a theft, whereas KRS 508.”
Jones v. United States, 526 U.S. 227 (1999). · cites it 4× “§ 21-3427 (1995) (aggravated robbery; "inflicts bodily harm"); Ky. Rev. Stat. Ann. § 515.020 (1)(a) (Michie 1990) (robbery in the first degree; "causes physical injury"); N.”
Thacker v. Commonwealth, 194 S.W.3d 287 (Ky. 2006). · cites it 10× “020 sets forth Robbery in the First Degree, in pertinent part, as follows: A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft…”
Lawless v. Commonwealth, 323 S.W.3d 676 (Ky. 2010). · cites it 13× “Kristy Lawless appeals from a December 16, 2008 Judgment of the Jefferson Circuit Court convicting her, in accord with the jury’s verdict, of robbery in the first degree, in violation of KRS 515.020. Pursuant to Lawless’s plea acknowledging her status as a first-degree…”
Thomas v. Commonwealth, 931 S.W.2d 446 (Ky. 1996). · cites it 8× “We noted that the robbery statute, KRS 515.020, provided that a robbery can only be committed against a person.”
Travis v. Commonwealth, 327 S.W.3d 456 (Ky. 2010). · cites it 4× “See KRS 515.020. As long as the jury finds from the evidence that Travis and Dawson either "stole" or "attempted to steal" property from Humphrey, it is not critical as to which one to find them guilty of first-degree robbery.”
Stark v. Commonwealth, 828 S.W.2d 603 (Ky. 1991). · cites it 10× “KRS 515.020 provides: A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical injury to any person…”
Gamble v. Commonwealth, 319 S.W.3d 375 (Ky. 2010). · cites it 24× “[2] KRS 515.020 (the first-degree robbery statute), incorporates all the elements of second-degree robbery, [3] but also requires one of three aggravating circumstances, which are listed in KRS 515.”
Williams v. Commonwealth, 721 S.W.2d 710 (Ky. 1986). · cites it 9× “KRS 515.020, Robbery in the first degree, reads: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a)…”
Meece v. Commonwealth, 348 S.W.3d 627 (Ky. 2011). · cites it 3× “” Robbery in the first degree, KRS 515.020, is committed: [W]hen, in the course of committing theft, [a person] uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical injury to any person who…”
Show all 193 citing cases →
— Ky. Rev. Stat. § 515.020(1) — 29 cases
Lloyd v. Commonwealth, 324 S.W.3d 384 (Ky. 2010). “Robbery in the first degree, for which Lloyd was indicted and convicted, is governed by KRS 515.020, which has not been amended since first enacted in 1974.”
Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999). “[2] It is unnecessary to the decision in this case to address whether double jeopardy is avoided by the fact that KRS 515.020 requires proof that the defendant acted with the intent to accomplish a theft, whereas KRS 508.”
Thacker v. Commonwealth, 194 S.W.3d 287 (Ky. 2006). “020 sets forth Robbery in the First Degree, in pertinent part, as follows: A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft…”
Whorton v. Commonwealth, 570 S.W.2d 627 (Ky. 1978).
Thompson v. Commonwealth, 862 S.W.2d 871 (Ky. 1993).
— Ky. Rev. Stat. § 515.020(1)(a) — 12 cases
Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999). “[2] It is unnecessary to the decision in this case to address whether double jeopardy is avoided by the fact that KRS 515.020 requires proof that the defendant acted with the intent to accomplish a theft, whereas KRS 508.”
Kenyatta Erkins v. State of Indiana, 13 N.E.3d 400 (Ind. 2014).
Gamble v. Commonwealth, 319 S.W.3d 375 (Ky. 2010). “[2] KRS 515.020 (the first-degree robbery statute), incorporates all the elements of second-degree robbery, [3] but also requires one of three aggravating circumstances, which are listed in KRS 515.”
Timothy Hatton v. Commonwealth of Kentucky (Ky. 2016).
Commonwealth of Kentucky v. Perry Jack Probus, Jr. (Ky. Ct. App. 2023).
— Ky. Rev. Stat. § 515.020(1)(b) — 11 cases
Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999). “[2] It is unnecessary to the decision in this case to address whether double jeopardy is avoided by the fact that KRS 515.020 requires proof that the defendant acted with the intent to accomplish a theft, whereas KRS 508.”
Wilburn v. Commonwealth, 312 S.W.3d 321 (Ky. 2010). “[3] KRS 515.020 provides as follows: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical…”
Barth v. Commonwealth, 80 S.W.3d 390 (Ky. 2001).
Meece v. Commonwealth, 348 S.W.3d 627 (Ky. 2011). “” Robbery in the first degree, KRS 515.020, is committed: [W]hen, in the course of committing theft, [a person] uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical injury to any person who…”
Mishler v. Commonwealth, 556 S.W.2d 676 (Ky. 1977).
— Ky. Rev. Stat. § 515.020(1)(c) — 7 cases
Meece v. Commonwealth, 348 S.W.3d 627 (Ky. 2011). “” Robbery in the first degree, KRS 515.020, is committed: [W]hen, in the course of committing theft, [a person] uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical injury to any person who…”
Gamble v. Commonwealth, 319 S.W.3d 375 (Ky. 2010). “[2] KRS 515.020 (the first-degree robbery statute), incorporates all the elements of second-degree robbery, [3] but also requires one of three aggravating circumstances, which are listed in KRS 515.”
Thacker v. Commonwealth, 194 S.W.3d 287 (Ky. 2006). “020 sets forth Robbery in the First Degree, in pertinent part, as follows: A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft…”
Crawley v. Commonwealth, 107 S.W.3d 197 (Ky. 2003).
Williams v. Commonwealth, 721 S.W.2d 710 (Ky. 1986). “KRS 515.020, Robbery in the first degree, reads: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a)…”
— Ky. Rev. Stat. § 515.020(2) — 5 cases
Lloyd v. Commonwealth, 324 S.W.3d 384 (Ky. 2010). “Robbery in the first degree, for which Lloyd was indicted and convicted, is governed by KRS 515.020, which has not been amended since first enacted in 1974.”
Isaiah Tyler v. Dep't of Corr. (Ky. Ct. App. 2021).
Grady v. Commonwealth, 561 S.W.3d 357 (Ky. Ct. App. 2018).
Marcus Britt v. Commonwealth of Kentucky (Ky. Ct. App. 2022).
Genesson Beraut v. Commonwealth of Kentucky (Ky. Ct. App. 2023).
— Ky. Rev. Stat. § 515.020(a) — 2 cases
McNeil v. Commonwealth, 468 S.W.3d 858 (Ky. 2015).
Archie Lee Williams v. Commonwealth of Kentucky (Ky. Ct. App. 2023).
— Ky. Rev. Stat. § 515.020(a)(1) — 1 case
United States v. Ingram, 276 F. Supp. 3d 717 (E.D. Ky. 2017).
— Ky. Rev. Stat. § 515.020(b) — 4 cases
Lawless v. Commonwealth, 323 S.W.3d 676 (Ky. 2010). “Kristy Lawless appeals from a December 16, 2008 Judgment of the Jefferson Circuit Court convicting her, in accord with the jury’s verdict, of robbery in the first degree, in violation of KRS 515.020. Pursuant to Lawless’s plea acknowledging her status as a first-degree…”
Wilburn v. Commonwealth, 312 S.W.3d 321 (Ky. 2010). “[3] KRS 515.020 provides as follows: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical…”
Wiley v. Commonwealth, 348 S.W.3d 570 (Ky. 2010).
Birdsong v. Commonwealth, 347 S.W.3d 47 (Ky. 2011).
— Ky. Rev. Stat. § 515.020(c) — 2 cases
Lawless v. Commonwealth, 323 S.W.3d 676 (Ky. 2010). “Kristy Lawless appeals from a December 16, 2008 Judgment of the Jefferson Circuit Court convicting her, in accord with the jury’s verdict, of robbery in the first degree, in violation of KRS 515.020. Pursuant to Lawless’s plea acknowledging her status as a first-degree…”
McNeil v. Commonwealth, 468 S.W.3d 858 (Ky. 2015).
— Ky. Rev. Stat. § 515.020(l)(a) — 11 cases
Oakes v. Commonwealth, 320 S.W.3d 50 (Ky. 2010).
Howell v. Commonwealth, 296 S.W.3d 430 (Ky. Ct. App. 2009).
Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999). “[2] It is unnecessary to the decision in this case to address whether double jeopardy is avoided by the fact that KRS 515.020 requires proof that the defendant acted with the intent to accomplish a theft, whereas KRS 508.”
Hobson v. Commonwealth, 306 S.W.3d 478 (Ky. 2010).
Sherley v. Commonwealth, 558 S.W.2d 615 (Ky. 1977).
— Ky. Rev. Stat. § 515.020(l)(b) — 13 cases
Wilburn v. Commonwealth, 312 S.W.3d 321 (Ky. 2010). “[3] KRS 515.020 provides as follows: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a) Causes physical…”
Wiley v. Commonwealth, 348 S.W.3d 570 (Ky. 2010).
Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999). “[2] It is unnecessary to the decision in this case to address whether double jeopardy is avoided by the fact that KRS 515.020 requires proof that the defendant acted with the intent to accomplish a theft, whereas KRS 508.”
Slaven v. Commonwealth, 962 S.W.2d 845 (Ky. 1997).
Oakes v. Commonwealth, 320 S.W.3d 50 (Ky. 2010).
— Ky. Rev. Stat. § 515.020(l)(c) — 8 cases
Gamble v. Commonwealth, 319 S.W.3d 375 (Ky. 2010). “[2] KRS 515.020 (the first-degree robbery statute), incorporates all the elements of second-degree robbery, [3] but also requires one of three aggravating circumstances, which are listed in KRS 515.”
Thacker v. Commonwealth, 194 S.W.3d 287 (Ky. 2006). “020 sets forth Robbery in the First Degree, in pertinent part, as follows: A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft…”
Crawley v. Commonwealth, 107 S.W.3d 197 (Ky. 2003).
Oakes v. Commonwealth, 320 S.W.3d 50 (Ky. 2010).
Williams v. Commonwealth, 721 S.W.2d 710 (Ky. 1986). “KRS 515.020, Robbery in the first degree, reads: (1) A person is guilty of robbery in the first degree when, in the course of committing theft, he uses or threatens the immediate use of physical force upon another person with intent to accomplish the theft and when he: (a)…”
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