Corona v. State
The Second District held that the trial court erred by refusing to instruct the jury on robbery by sudden snatching as a category two lesser-included offense of robbery, where the information alleged the taking was accomplished by force, violence, assault, or putting the victim in fear. Relying on the First District's decision in Clark v. State, the court held that an allegation of putting the victim in fear necessarily alleges the victim became aware of the taking during the course of the taking, satisfying the elements of sudden snatching. The court reversed Corona's robbery conviction and remanded for a new trial on that count only, affirming the other convictions without comment.
Key facts
- Corona was charged with robbery alleged to have been accomplished by force, violence, assault, or putting the victim in fear, along with felony domestic battery and a pretrial release violation.
- At trial, the trial court refused Corona's request for a jury instruction on robbery by sudden snatching as a lesser-included offense of the charged robbery.
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Why it matters
This decision reinforces and extends the First District's reasoning in Clark v. State to the Second District, giving practitioners a clearer, district-aligned rule that charging a robbery via 'putting in fear'… — full analysis with a trial
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