California, United States of America
The following excerpt is from People v. Woods, B239866 (Cal. App. 2013):
6. People v. Estes (1983) 147 Cal.App.3d 23. The case established that the use of force to prevent a security guard from regaining possession of property elevated a petty theft to a robbery.
7. The Attorney General argues that defendant failed to establish a prima facie case of group bias; however, given the trial court's ruling to the contrary, the issue is moot. (People v. Lenix (2008) 44 Cal.4th 602, 613, fn. 8.)
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