In In Re: Jason Mills, 11th Dist. No. 2001-A-0028, 2002 Ohio 3125, the defendant had stolen money from a store safe. As the defendant exited the store office, the store manager pinned him against the wall and retrieved the money. The defendant pushed the manager and ran out of the store. On appeal, the defendant argued that the force he used against the manager did not occur simultaneously with the theft; thus, the state failed to prove the required element of force necessary to convict him of robbery. The Court rejected the defendant's argument, holding instead that "the use of force need not be in furtherance of the theft, as long as it occurs while the appellant is immediately fleeing from the attempt or the commission of the theft offense." Id. at P23. The Court further stressed that even if a defendant has already left the store, he or she may still be convicted of robbery. In fact, "where a defendant struggles with store security guards outside a store immediately after a theft in an effort to escape apprehension, such conduct is sufficient to establish the force element of robbery." Id. at P22.