In People v. Cochran, 10 A.D.3d 563 (1st Dept. 2004), the First Department held that a conviction for robbery in Maryland could not be used as a predicate felony conviction in New York inasmuch as the Maryland robbery statute does not require an intent to steal "at the time force is employed." The court therefore concluded that "since a person may thus be convicted in Maryland of a felony for conduct that would not be felonious in New York, defendant's Maryland robbery conviction does not qualify as a predicate felony."