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People v. Anderson - 51 Cal. 4th 989, 125 Cal. Rptr. 3d 408, 252 P.3d 968 (2011)

Rule:

The intent element of robbery does not include an intent to apply force against the victim or to cause the victim to feel fear. It is robbery if the defendant committed a forcible act against the victim motivated by the intent to steal, even if the defendant did not also intend for the victim to experience force or fear.

Facts:

While stealing a car, defendant Paul Anderson ran over the owner, causing her death. He did not deny hitting her, but claimed it was an accident. A jury found him guilty of first degree felony murder with the special circumstance of killing during the course of a robbery, robbery, and receipt of stolen property. Defendant appealed, arguing that the trial court erred by failing to provide a sua sponte instruction on accident as a defense to the crime of robbery, thus requiring reversal not only of his robbery conviction, but also of his conviction of first degree felony murder and the special circumstance. The Court of Appeal agreed, and reversed defendant’s conviction. The State sought further review.

Issue:

  1. Was the intent to apply force an essential element of robbery, thereby rendering “accident” a valid defense to the crime?
  2. Did the district court have the obligation to provide a sua sponte instruction on accident as a defense to the crime of robbery?

Answer:

1) No. 2) No.

Conclusion:

The Court held that the intent element of robbery did not include intent to apply force against the victim or to cause the victim to feel fear. According to the Court, it was robbery if the defendant committed a forcible act against the victim motivated by the intent to steal, even if the defendant did not also intend for the victim to experience force or fear. In the current case, the evidence of defendant's intent was sufficient, even if he did not intend to strike or frighten the owner of the car. Even under his version of the facts, he drove the car with more force than necessary to move it to a place of safety, in order to retain the property and facilitate his escape. The Court also held that the trial court did not have a duty to instruct sua sponte on accident as a defense. The Court averred that the responsibility to instruct on accident generally extends no further than the obligation to provide, upon request, a pinpoint instruction relating the evidence to the mental element required for the charged crime. Further, an accident instruction would have been improper, even upon defense request, given that defendant's theory of accident added a nonexistent element to the offense.

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