In In re Jesus O. (2007) 40 Cal.4th 859, the victim was assaulted after refusing to give Jesus and another juvenile money. The victim was able to escape, but his cell phone fell out of his pocket while he was fleeing. He looked back and saw one of his attackers pick it up. (Id. at pp. 861-862.) The juvenile court found Jesus committed grand theft from the person and attempted robbery. The Supreme Court upheld these findings, but noted in dicta that "on these facts . . . it appears the court could have found the juvenile committed a completed robbery of the telephone." (Id. at p. 869, fn. 2.)