California, United States of America
The following excerpt is from People v. Hardy, E060163 (Cal. App. 2015):
victim's immediate presence when it is "'"'so within his reach, inspection, observation or control, that he could, if not overcome by violence or prevented by fear, retain his possession of it.'"'" (People v. Abilez, supra, 41 Cal.4th at p. 507.)
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