Does a purse snatch constitute a lesser included crime?

Consequently, if an instruction on such lesser included offense is requested on retrial, it must be given." (Id. at p. 787, fn. 1.) In contrast, where there is evidence of any struggle over the purse, the courts have concluded no lesser included offense instruction is necessary. (See, e.g., People v. Cooksey (2002) 95 Cal.App.4th 1407, 1411; People v. Burns, supra, 172 Cal.App.4th at pp. 1257-1259 ["We have found no California case holding that a purse snatch cannot qualify as a robbery . . . [and] . . . whether it does depends on the force used. [Fn. omitted.]"].)