Does Force Which Is Unlikely to Cause Injury to Victim Support a Robbery Conviction ?
In State v. Furlow (1992), 80 Ohio App.3d 146, 608 N.E.2d 1112, the defendant asked the victim for change for a five dollar bill.
The defendant then fled after snatching a wallet and five single dollar bills from the victim's hands. Id. at 149. the element of "force" was that the defendant snatched these items from the victim's "firmer than usual grip," which occurred after the victim became aware of the defendant's intent.
At that point, the victim tried to hold on to the wallet and bills more firmly, but the defendant pulled them out and ran away.
The Court concluded this was insufficient force to support a robbery conviction because the force did not pose actual or potential harm to the victim. Id.