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Name: People v. Johnson
Case #: A111007
Opinion Date: 07/31/2006
Division: 4
Citation: 141 Cal.App.4th 1161

A defendant’s use of force or fear to prevent a security guard from recovering stolen property is sufficient to support a conviction for robbery. Security guards watching a surveillance video observed the defendant stealing items from a grocery store. They confronted him after he left the store, and the defendant threatened to shoot them. The guards allowed him to leave. On appeal, he argued that the evidence at trial was not sufficient to support a robbery conviction. The Court of Appeal affirmed, holding that the force or fear element of robbery can be satisfied at any time until the stolen items are in a place of temporary safety.