Winn v. Commonwealth
In Winn v. Commonwealth, 21 Va. App. 179, 181, 462 S.E.2d 911, 912 (1995), the victim was walking through a parking lot when Winn approached from behind her.
He very strongly removed her purse strap from her shoulder and took her purse from under her arm. Id. at 180-81, 462 S.E.2d at 911-12.
During the theft Winn did not intimidate, touch, struggle with, knock down, strike, or injure the victim.
The Court reversed Winn's robbery conviction and remanded.
The Court found that the "very strong" force employed by Winn was merely the force necessary to remove the purse from the victim's shoulder, not force associated with violence to the victim or employed to overcome resistance by her. Id. at 184, 486 S.E.2d at 913.