Revised Code of Washington

Wash. Rev. Code § 9A.56.190 (2026)

✓ current as of May 2026
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A person commits robbery when he or she unlawfully takes personal property from the person of another or in his or her presence against his or her will by the use or threatened use of immediate force, violence, or fear of injury to that person or his or her property or the person or property of anyone. Such force or fear must be used to obtain or retain possession of the property, or to prevent or overcome resistance to the taking; in either of which cases the degree of force is immaterial. Such taking constitutes robbery whenever it appears that, although the taking was fully completed without the knowledge of the person from whom taken, such knowledge was prevented by the use of force or fear.
[ 2011 c 336 s 379; 1975 1st ex.s. c 260 s 9A.56.190.]
Notes of Decisions
Cited in 338 cases (47 in the last 5 years), 1977–2026 · leading case: State v. Tvedt, 153 Wash. 2d 705 (Wash. 2005).
State v. Tvedt, 153 Wash. 2d 705 (Wash. 2005). · cites it 18× “” Under the plain language of the statute, the crime of robbery requires that there be a taking of property and that the taking be forcible and against the will of the person from whom or from whose presence the property is taken.”
State v. Tvedt, 107 P.3d 728 (Wash. 2005). · cites it 17× “" Under the plain language of the statute, the crime of robbery requires that there be a taking of property and that the taking be forcible and against the will of the person from whom or from whose presence the property is taken.”
State v. Witherspoon, 329 P.3d 888 (Wash. 2014). · cites it 5× “190: A person commits robbery when he or she unlawfully takes personal property from the person of another or in his or her presence against his or her will by the use or threatened use of immediate force, violence, or fear of injury to that person or his or her property or the…”
McKenzy Alfred v. Merrick Garland, 64 F.4th 1025 (9th Cir. 2023). · cites it 8× “§ 1101 (a)(43)(G), the en banc court held that second-degree robbery under Wash. Rev. Code § 9A.56.190 is a categorical match with generic theft and is therefore a theft offense under § 1101(a)(43)(G).”
State Of Washington, V. Christopher Lee Derri, 486 P.3d 901 (Wash. Ct. App. 2021). · cites it 10× “RCW 9A.56.190 (emphasis added). Here, Derri contends that the information, with regard to all three counts of robbery in the first degree, did not properly set forth the essential elements of the 8 No.”
State v. Kjorsvik, 812 P.2d 86 (Wash. 1991). · cites it 4× “*98 Although our robbery statute, RCW 9A.56.190, does not include an intent element, [2] our settled case law is clear that "intent to steal" is an essential element of the crime of robbery.”
State v. Vladovic, 662 P.2d 853 (Wash. 1983). · cites it 4× “*418 RCW 9A.56.190. (1) A person is guilty of robbery in the first degree if in the commission of a robbery or of immediate flight therefrom, he: .”
Fields v. Wash. Dep't of Early Learning, 434 P.3d 999 (Wash. 2019). · cites it 4× “RCW 9A.56.190. This court has held that "'[t]he nature of the crime of robbery includes the threat of violence against another person.”
State v. Handburgh, 830 P.2d 641 (Wash. 1992). · cites it 6× “At issue is what constitutes a forcible taking "in the presence of" another under RCW 9A.56.190. On August 11, 1989, 12-year-old Chaska Leonard left her bicycle unattended outside a Tacoma recreation center while she went inside.”
State v. Knight, 309 P.3d 776 (Wash. Ct. App. 2013). · cites it 4× “190, which provides that a person commits robbery “when he or she unlawfully takes personal property from the person of another or in his or her presence against his or her will by the use or threatened use of immediate force, violence, or fear of injury *954 to that person.”
State v. Davis, 618 P.2d 1034 (Wash. Ct. App. 1980). · cites it 6× “200(l)(b) and RCW 9A.56.190, while armed with a deadly weapon, RCW 9.”
State v. Witherspoon, 286 P.3d 996 (Wash. Ct. App. 2012). · cites it 5× “See RCW 9A.56.190. Witherspoon contends that because the information fails to allege all the essential facts supporting every element of second degree robbery, specifically the use or threatened use of force, it is thereby defective.”
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