California, United States of America
The following excerpt is from People v. Wilkerson, B225838 (Cal. App. 2011):
Even if property is initially taken without use of force or fear, the crime may become a robbery if force or fear is used to hold onto the property while it is being carried away. (People v. Cooper (1991) 53 Cal.3d 1158, 1165, fn. 8 (Cooper) ["mere theft becomes robbery if the perpetrator, having gained possession of the property without use of force or fear, resorts to force or fear while carrying away the loot"]; Estes,
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