Montana Code Annotated

Mont. Code Ann. § 45-5-401 (2026)

Robbery

✓ current as of May 2026
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TITLE 45. CRIMES

CHAPTER 5. OFFENSES AGAINST THE PERSON

Part 4. Robbery

Robbery

45-5-401. Robbery. (1) A person commits the offense of robbery if in the course of committing a theft, the person:

(a) inflicts bodily injury upon another;

(b) threatens to inflict bodily injury upon any person or purposely or knowingly puts any person in fear of immediate bodily injury; or

(c) commits or threatens immediately to commit any felony other than theft.

(2) A person convicted of the offense of robbery shall be imprisoned in the state prison for a term of not less than 2 years or more than 40 years and may be fined not more than $50,000, except as provided in 46-18-219 and 46-18-222.

(3) "In the course of committing a theft", as used in this section, includes acts that occur in an attempt to commit or in the commission of theft or in flight after the attempt or commission.

History: En. 94-5-401 by Sec. 1, Ch. 513, L. 1973; amd. Sec. 9, Ch. 584, L. 1977; R.C.M. 1947, 94-5-401; amd. Sec. 7, Ch. 198, L. 1981; amd. Sec. 7, Ch. 482, L. 1995.

Notes of Decisions
Cited in 85 cases (7 in the last 5 years), 1979–2026 · leading case: State v. Madera, 670 P.2d 552 (Mont. 1983).
State v. Madera, 670 P.2d 552 (Mont. 1983). · cites it 21× “The count of robbery was based upon section 45-5-401(1)(a), MCA, charging that LaMere "in the course of committing a theft, purposely or knowingly inflicted bodily injury upon [a woman].”
Fitzpatrick v. State, 638 P.2d 1002 (Mont. 1981). · cites it 18× “Section 45-5-401, MCA provides: “(1) A person commits the offense of robbery if in the course of committing a theft he: “(a) inflicts bodily injury upon another; “(b) threatens to inflict bodily injury upon any person or purposely or knowingly puts any person in fear of…”
State v. Greywater, 939 P.2d 975 (Mont. 1997). · cites it 22× “Section 45-5-401, MCA, requires only that the actor "be in the course of committing the theft.”
State v. Greywater, 939 P.2d 975 (Mont. 1997). · cites it 20× “Section 45-5-401, MCA, requires only that the actor “be in the course of committing the theft.”
State v. Krantz, 788 P.2d 298 (Mont. 1990). · cites it 14× “Compare § 45-5-401, MCA (1989) with Laws of Mont.”
State v. Close, 623 P.2d 940 (Mont. 1981). · cites it 6× “On June 3, 1976, the jury found defendant guilty of the following crimes, all arising out of one incident: Count I, deliberate homicide, section 45-5-102, MCA; Count II, aggravated kidnapping, section 45-5-303 MCA; and Count III, robbery, section 45-5-401, MCA. On June 10, 1976,…”
State v. Lester Kills on Top, 787 P.2d 336 (Mont. 1990). · cites it 6× “] Theft is defined in § 45-6-301, MCA, which provides: Theft. (1) A person commits the offense of theft when he purposely or *341 knowingly obtains or exerts unauthorized control over property of the owner and: (a) has the purpose of depriving the owner of the property[.”
State v. Ritchson, 630 P.2d 234 (Mont. 1981). · cites it 10× “” The offense of robbery is defined by section 45-5-401, MCA, as follows: “(1) A person commits the offense of robbery if in the course of committing a theft he: “(a) inflicts bodily injury upon another; “(b) threatens to inflict bodily injury upon any person in fear of…”
State v. Ferguson, 2005 MT 343 (Mont. 2005). · cites it 3× “Section 45-5-401(l)(b), MCA, provides, in pertinent part, that a person commits the offense of robbery if, in the course of committing a theft, the person threatens to inflict bodily injury upon any person, or purposely or knowingly puts any person in fear of immediate bodily…”
State v. Van Kirk, 2001 MT 184 (Mont. 2001). · cites it 2× “Assume, for example, that the accused is charged with robbery under § 45-5-401(l)(b), MCA. The only evidence of the defendant's threat to inflict bodily injury on the liquor store clerk (the threat being an essential element of the crime charged) is the repetition by the…”
State v. Owens, 20 S.W.3d 634 (Tenn. 2000). · cites it 4× “24 (West 1987); Mont.Code Ann. § 45-5-401 (West 1999); Nev.”
State v. Hembd, 838 P.2d 412 (Mont. 1992). · cites it 5× “Hembd was sentenced to twenty-five years for robbery pursuant to § 45-5-401, MCA; the sentence was within the 40-year maximum statutory sentence for robbery.”
— Mont. Code Ann. § 45-5-401(1) — 5 cases
Fitzpatrick v. State, 638 P.2d 1002 (Mont. 1981). “Section 45-5-401, MCA provides: “(1) A person commits the offense of robbery if in the course of committing a theft he: “(a) inflicts bodily injury upon another; “(b) threatens to inflict bodily injury upon any person or purposely or knowingly puts any person in fear of…”
United States v. Pedro Santiesteban-Hernandez, 469 F.3d 376 (5th Cir. 2006).
State v. Lester Kills on Top, 787 P.2d 336 (Mont. 1990). “] Theft is defined in § 45-6-301, MCA, which provides: Theft. (1) A person commits the offense of theft when he purposely or *341 knowingly obtains or exerts unauthorized control over property of the owner and: (a) has the purpose of depriving the owner of the property[.”
State v. Preston Hanna, 2014 MT 346 (Mont. 2014).
State, City of Great Falls v. Ross, 2008 MT 369 (Mont. 2008).
— Mont. Code Ann. § 45-5-401(1)(a) — 4 cases
State v. Madera, 670 P.2d 552 (Mont. 1983). “The count of robbery was based upon section 45-5-401(1)(a), MCA, charging that LaMere "in the course of committing a theft, purposely or knowingly inflicted bodily injury upon [a woman].”
State v. Greywater, 939 P.2d 975 (Mont. 1997). “Section 45-5-401, MCA, requires only that the actor "be in the course of committing the theft.”
State v. Lester Kills on Top, 787 P.2d 336 (Mont. 1990). “] Theft is defined in § 45-6-301, MCA, which provides: Theft. (1) A person commits the offense of theft when he purposely or *341 knowingly obtains or exerts unauthorized control over property of the owner and: (a) has the purpose of depriving the owner of the property[.”
State v. Martin, 435 P.3d 73 (Mont. 2019).
— Mont. Code Ann. § 45-5-401(1)(b) — 11 cases
State v. Madera, 670 P.2d 552 (Mont. 1983). “The count of robbery was based upon section 45-5-401(1)(a), MCA, charging that LaMere "in the course of committing a theft, purposely or knowingly inflicted bodily injury upon [a woman].”
Pena v. State, 2004 MT 293 (Mont. 2004).
State v. S. Llamas, 2017 MT 155 (Mont. 2017).
Watson v. State, 2002 MT 329 (Mont. 2002).
State v. Albrecht, 791 P.2d 760 (Mont. 1990).
— Mont. Code Ann. § 45-5-401(2) — 4 cases
Vernon Kills on Top v. State, 2000 MT 340 (Mont. 2000).
State v. Youpee, 416 P.3d 1050 (Mont. 2018).
Matter of D.C. Jr. a Youth, 2014 MT 292N (Mont. 2014).
State v. Bull Coming, 831 P.2d 578 (Mont. 1992).
— Mont. Code Ann. § 45-5-401(3) — 7 cases
United States v. Garcia-Caraveo, 586 F.3d 1230 (10th Cir. 2009).
State v. Preston Hanna, 2014 MT 346 (Mont. 2014).
State v. R.S.A., 2015 MT 202 (Mont. 2015).
State v. R.S.A., 2015 MT 202 (Mont. 2015).
State v. P. Rossbach, 2024 MT 157 (Mont. 2024).
— Mont. Code Ann. § 45-5-401(c) — 1 case
Fitzpatrick v. State, 638 P.2d 1002 (Mont. 1981). “Section 45-5-401, MCA provides: “(1) A person commits the offense of robbery if in the course of committing a theft he: “(a) inflicts bodily injury upon another; “(b) threatens to inflict bodily injury upon any person or purposely or knowingly puts any person in fear of…”
— Mont. Code Ann. § 45-5-401(l)(a) — 6 cases
State v. Greywater, 939 P.2d 975 (Mont. 1997). “Section 45-5-401, MCA, requires only that the actor “be in the course of committing the theft.”
State v. Madera, 670 P.2d 552 (Mont. 1983). “The count of robbery was based upon section 45-5-401(1)(a), MCA, charging that LaMere "in the course of committing a theft, purposely or knowingly inflicted bodily injury upon [a woman].”
State v. Langford, 813 P.2d 936 (Mont. 1991).
State v. J. Nixon, 2013 MT 81 (Mont. 2013).
State v. Renee, 1999 MT 135 (Mont. 1999).
— Mont. Code Ann. § 45-5-401(l)(b) — 15 cases
State v. Ferguson, 2005 MT 343 (Mont. 2005). “Section 45-5-401(l)(b), MCA, provides, in pertinent part, that a person commits the offense of robbery if, in the course of committing a theft, the person threatens to inflict bodily injury upon any person, or purposely or knowingly puts any person in fear of immediate bodily…”
State v. Van Kirk, 2001 MT 184 (Mont. 2001). “Assume, for example, that the accused is charged with robbery under § 45-5-401(l)(b), MCA. The only evidence of the defendant's threat to inflict bodily injury on the liquor store clerk (the threat being an essential element of the crime charged) is the repetition by the…”
State v. Madera, 670 P.2d 552 (Mont. 1983). “The count of robbery was based upon section 45-5-401(1)(a), MCA, charging that LaMere "in the course of committing a theft, purposely or knowingly inflicted bodily injury upon [a woman].”
Fitzpatrick v. State, 638 P.2d 1002 (Mont. 1981). “Section 45-5-401, MCA provides: “(1) A person commits the offense of robbery if in the course of committing a theft he: “(a) inflicts bodily injury upon another; “(b) threatens to inflict bodily injury upon any person or purposely or knowingly puts any person in fear of…”
State v. Bailey, 2003 MT 150 (Mont. 2003).
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