C.A.
v.
STATE
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The evidence was sufficient to prove the lesser offense of robbery by sudden snatching, which does not require force beyond that necessary to obtain possession of the property.
[1] Robbery by sudden snatching does not require the offender to use or threaten to use force or violence beyond that necessary to obtain possession of property.
[2] In reviewing a motion for judgment of dismissal, all facts and evidence adduced are admitted, and all reasonable inferences are viewed in a light most favorable to the st…
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Join FLexlaw to unlock all legal intelligence“Robbery by sudden snatching does not require that the offender use or threaten to use any force or violence in order to commit the crime of robbery by sudden snatching. In fact, no force whatsoever is required 'beyond that effort necessary to obtain possession of the money or other property'”
Court's explanation of the statutory definition of robbery by sudden snatching under Florida law
C.A., a juvenile, was charged with strongarm robbery. At the adjudicatory hearing, the trial court found the evidence insufficient for strongarm robbe…
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Third District Court of Appeal
State of Florida
Opinion filed October 10, 2018. Not final until disposition of timely filed motion for rehearing.
________________
No. 3D18-267 Lower Tribunal No. 17-2066
________________
C.A., a juvenile,
Appellant,
vs.
The State of Florida,
Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Teresa Mary Pooler, Judge.
Carlos J. Martinez, Public Defender, and Stephen Weinbaum, Assistant Public Defender, for appellant.
Pamela Jo Bondi, Attorney General, and Christina L. Dominguez, Assistant Attorney General, for appellee.
Before ROTHENBERG, C.J., and EMAS and LINDSEY, JJ.
PER CURIAM.
C.A., a juvenile, was charged by petition with committing strongarm robbery. At the conclusion of the adjudicatory hearing, C.A. moved for a judgment of dismissal,1 contending that the evidence did not support strongarm robbery or robbery by sudden snatching, but merely petit theft. The trial court agreed the evidence was insufficient to establish strongarm robbery, but sufficient to prove the lesser offense of robbery by sudden snatching. The trial court found
C.A. delinquent, but withheld adjudication and placed C.A. on probation.
C.A. appeals the trial court’s determination, asserting that the evidence did not establish robbery by sudden snatching, but only petit theft.2 See A.M. v. State, 147 So. 3d 98, 100 (Fla. 3d DCA
2014) (holding that robbery by sudden snatching “does not require that the offender use or threaten to use any force or violence in order to commit the crime of robbery by sudden snatching. In fact, no force whatsoever is required ‘beyond
that effort necessary to obtain possession of the money or other property’”) (quoting section 812.131, Fla. Stat. (2014) and Fla. Std. J. Inst. (Crim.) 15.4)).
We also reject C.A.’s argument that the evidence established the victim consented to C.A.’s taking of the property. While there were inconsistencies in the evidence, such inconsistences presented questions of weight and credibility to be accorded the evidence. These issues were resolved by the trial court as the finder of fact, and we will not substitute our judgment for that of the factfinder. Miller v.
State, 328 So. 2d 544 (Fla. 3d DCA 1976). Viewing the evidence in a light most favorable to sustaining the trial court’s determinations, we hold that the evidence was sufficient to conclude that the victim did not consent to the taking, and that a prima facie case of guilt was established for the crime of robbery by sudden snatching. J.H. v. State, 220 So. 3d 508, 510 (Fla. 3d DCA 2017) (citing C.E.L. v.
State, 995 So. 2d 558, 560 (Fla. 2d DCA 2008) (approved, 24 So. 3d 1181 (Fla.
2009)).
Affirmed.
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