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Florida Statute 812.131 | Lawyer Caselaw & Research
F.S. 812.131 Case Law from Google Scholar
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The 2023 Florida Statutes (including Special Session C)

Title XLVI
CRIMES
Chapter 812
THEFT, ROBBERY, AND RELATED CRIMES
View Entire Chapter
F.S. 812.131
812.131 Robbery by sudden snatching.
(1) “Robbery by sudden snatching” means the taking of money or other property from the victim’s person, with intent to permanently or temporarily deprive the victim or the owner of the money or other property, when, in the course of the taking, the victim was or became aware of the taking. In order to satisfy this definition, it is not necessary to show that:
(a) The offender used any amount of force beyond that effort necessary to obtain possession of the money or other property; or
(b) There was any resistance offered by the victim to the offender or that there was injury to the victim’s person.
(2)(a) If, in the course of committing a robbery by sudden snatching, the offender carried a firearm or other deadly weapon, the robbery by sudden snatching is a felony of the second degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.
(b) If, in the course of committing a robbery by sudden snatching, the offender carried no firearm or other deadly weapon, the robbery by sudden snatching is a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.
(3)(a) An act shall be deemed “in the course of committing a robbery by sudden snatching” if the act occurs in an attempt to commit robbery by sudden snatching or in fleeing after the attempt or commission.
(b) An act shall be deemed “in the course of the taking” if the act occurs prior to, contemporaneous with, or subsequent to the taking of the property and if such act and the act of taking constitute a continuous series of acts or events.
History.s. 1, ch. 99-175.

F.S. 812.131 on Google Scholar

F.S. 812.131 on Casetext

Amendments to 812.131


Arrestable Offenses / Crimes under Fla. Stat. 812.131
Level: Degree
Misdemeanor/Felony: First/Second/Third

S812.131 2a - ROBBERY - BY SUDDEN SNATCHING W FIREARM OR WEAPON - F: S
S812.131 2b - ROBBERY - BY SUDDEN SNATCHING WO FIREARM OR WEAPON - F: T



Annotations, Discussions, Cases:

Cases from cite.case.law:

STOKELING, v. UNITED STATES., 139 S. Ct. 544 (U.S. 2019)

. . . . § 812.131 (1999). . . .

IN RE STANDARD JURY INSTRUCTIONS IN CRIMINAL CASES- REPORT, 260 So. 3d 941 (Fla. 2018)

. . . 10.4 Aggravated Battery 784.045 8.4 Grand theft -_second 812.014(2)(b) 14.1 degree Robbery by sudden 812.131 . . . firearm 790.07(2) 10.3 Aggravated Assault 784.021 8.2 Felony Battery 784.041 8.5 Robbery by Sudden 812.131 . . . 5.1 Aggravated Battery 784.045 8.4 Grand theft - second 812.014(2)(b) 14.1 degree Robbery by sudden 812.131 . . . firearm 790.07(2) 10.3 Aggravated Assault 784.021 8.2 Felony battery 784.041 8.5 Robbery by sudden 812.131 . . . firearm 790.07(2) 10.3 Aggravated Assault 784.021 8.2 Felony Battery 784.041 8.5 Robbery by sudden 812.131 . . .

C. A. a v. STATE, 255 So. 3d 520 (Fla. App. Ct. 2018)

. . . beyond that effort necessary to obtain possession of the money or other property' ") (quoting section 812.131 . . .

DOUGLAS, v. STATE, 239 So. 3d 157 (Fla. App. Ct. 2018)

. . . require evidence of any force beyond the effort necessary to obtain possession of the property, see § 812.131 . . . Stat. (2010), or that the victim offered any resistance, see § 812.131(1)(b). . . .

UNITED STATES v. STOKELING,, 684 F. App'x 870 (11th Cir. 2017)

. . . . § 812.131, categorically qualifies as a violent felony under the elements clause of the Armed Career . . .

SMITH, v. STATE, 211 So. 3d 176 (Fla. Dist. Ct. App. 2016)

. . . A robbery offense under s. 812.13, s. 812.131, or s. 812.135. 7. Carjacking under s. 812.133. 8. . . .

MATHIS, v. STATE, 204 So.3d 104 (Fla. Dist. Ct. App. 2016)

. . . A robbery offense undér s. 812.13, s. 812.131, or s. 812.135. 7. Carjacking under s. 812.133. 8. . . .

UNITED STATES v. FRITTS,, 841 F.3d 937 (11th Cir. 2016)

. . . In 1999, Florida enacted a wholly separate statute, § 812.131, which proscribes sudden snatching. . . . Stat. § 812.131 (1999) (emphasis added). . . .

UNITED STATES v. SEABROOKS,, 839 F.3d 1326 (11th Cir. 2016)

. . . . § 812.131, a “robbery by sudden snatching” statute. . . . Section 812.131 says that a person who takes property from a victim’s person with intent to deprive has . . . Sea-brooks argues that before Florida enacted § 812.131 in 1999, “sudden snatching” was enough to support . . . Thus, “sudden snatching” as defined by § 812.131—that is, taking property without “us[ing] any amount . . . . § 812.131; and (3) “Lockley analyzed this later scheme and held that this new version of § 812.13(1 . . . While Florida in 1999 did enact a new sudden snatching statute codified at § 812.131, Florida did not . . . Stat. § 812.131 (1999) (emphasis added). . . . .

IN RE JACKSON,, 826 F.3d 1343 (11th Cir. 2016)

. . . . § 812.131. . . .

UNITED STATES v. JENKINS,, 651 F. App'x 920 (11th Cir. 2016)

. . . the Florida Legislature enacted a separate robbery by sudden snatching statute, Florida Statutes § 812.131 . . . the Florida Legislature enacted a separate robbery by sudden snatching statute, Florida Statutes § 812.131 . . . Stat. § 812.131; 1999 Fla. . . . Stat. § 812.131(1)” because § 812.13(1) “concerns a far more aggressive and potentially violent form . . . that he was arrested, charged, and convicted under § 812.13(1) before Florida’s legislature enacted § 812.131 . . .

K. S. a v. STATE, 186 So. 3d 41 (Fla. Dist. Ct. App. 2016)

. . . is resting on a victim’s lap is considered taking “from the victim’s person” in violation of section 812.131 . . . ’s fingers are bent around it, is taking “from the victim’s person” as that term is used in section 812.131 . . .

UNITED STATES v. WILSON,, 641 F. App'x 908 (11th Cir. 2016)

. . . . § 812.131 (robbery by snatching), see D.E. 44 at 3, but § 812.131 had not been enacted in 1997, when . . .

J. CONNOLLY, Jr. v. STATE, 172 So. 3d 893 (Fla. Dist. Ct. App. 2015)

. . . See §§ 812.13(2)(a), 812.131(2)(a), 812.133(2)(a), Fla. Stat. (2015). . . . in an attempt to commit robbery by sudden snatching or in fleeing after the attempt or commission. § 812.131 . . .

O. A. a v. STATE, 146 So. 3d 135 (Fla. Dist. Ct. App. 2014)

. . . May 27, 2014, and charged with two third-degree felonies: (i) robbery by sudden snatching (section 812.131 . . .

A. M. a v. STATE, 147 So. 3d 98 (Fla. Dist. Ct. App. 2014)

. . . In 1999, the Florida Legislature enacted section 812.131, Florida Statutes, entitled “Robbery by Sudden . . . is a felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084. § 812.131 . . . requires proof that “in the course of the taking, the victim was or became aware of the taking.” § 812.131 . . .

T. ADAMS, v. STATE, 122 So. 3d 976 (Fla. Dist. Ct. App. 2013)

. . . See § 812.131, Fla. Stat. (2011). . . .

J. LAFFERTY, v. STATE, 114 So. 3d 1115 (Fla. Dist. Ct. App. 2013)

. . . with robbery by sudden snatching for the event that occurred on June 6, 2011, in violation of section 812.131 . . .

UNITED STATES v. WELCH,, 683 F.3d 1304 (11th Cir. 2012)

. . . . § 812.131 (2000). . Robinson v. . . .

WESS, v. STATE, 67 So. 3d 1133 (Fla. Dist. Ct. App. 2011)

. . . Appellant appeals his conviction of robbery by sudden snatching pursuant to section 812.131, Florida . . . s testimony did not establish that the purse was in her physical possession, as required by section 812.131 . . . Analysis Section 812.131, Florida Statutes (2010), provides, in relevant part: (1) “Robbery by sudden . . . Section 812.131(1), Florida Statutes, defines robbery as “the taking of money or other property which . . .

UNITED STATES v. D. LOCKLEY, a. k. a., 632 F.3d 1238 (11th Cir. 2011)

. . . . § 812.131(1), which concerns “robbery by sudden snatching.” . . . Stat. § 812.131(1). . . . Section 812.131(1) goes on to state that no force "beyond that effort necessary to obtain possession . . . So while § 812.131(1) attends to pick-pocketing or other similar activity (so long as the victim is in . . .

CLARK, v. STATE, 43 So. 3d 814 (Fla. Dist. Ct. App. 2010)

. . . lesser-included offense of “robbery by sudden snatching,” the third-degree felony proscribed by section 812.131 . . . necessarily alleges that the victim “in the course of the taking, ... was or became aware of the taking.” § 812.131 . . . 323 (Fla. 1st DCA 1996). .To prove the crime of robbery by sudden snatching in violation of section 812.131 . . .

UNITED STATES v. ONER,, 382 F. App'x 893 (11th Cir. 2010)

. . . . § 812.131(2)(a) does not qualify as a “violent felony” under the ACCA is likewise without merit. . . .

UNITED STATES v. BRYANT, Jr,, 312 F. App'x 698 (5th Cir. 2009)

. . . . § 812.131 (2)(b) (defining the offense as a "felony of the third degree"); id. § 775.082(3)(d) (indicating . . . Ann. § 812.131(1). . . . Id. § 812.131 (3)(b). . Brown v. State, 848 So.2d 361, 364 (Fla. . . . Ann. § 812.131(1) (emphasis added). . See Brown v. . . .

In STANDARD JURY INSTRUCTIONS IN CRIMINAL CASES- REPORT NO., 6 So. 3d 574 (Fla. 2009)

. . . Comment This instruction was adopted in 2009. 15.4 ROBBERY BY SUDDEN SNATCHING § 812.131, Fla. . . .

THOMAS, v. STATE, 983 So. 2d 746 (Fla. Dist. Ct. App. 2008)

. . . See §§ 316.1935(2), 812.131(1), Fla. Stat.; see also Yates v. . . .

In STANDARD JURY INSTRUCTIONS IN CRIMINAL CASES- REPORT NO., 982 So. 2d 1160 (Fla. 2008)

. . . 812.014(3)(a) 14.1 Attempt 777.04(1) 5.1 Robbery by sudden snatching with a firearm or deadly weapon 812.131 . . . (2)(a) 15.4 Robbery by sudden snatching 812.131(2)(b) 15.4 Grand theft — first degree 812.014(2)(a) 14.1 . . . by sudden snatching with a firearm or deadly weapon 812,131(2)(a) 15.4 Robbery by sudden snatching 812.131 . . . Petit theft-second degree_812.014(3)(a) 14.1 _Attempt_777.04(1)_5.1 _Robbery By Sudden Snatching 812.131 . . .

McCOLLUM, v. STATE, 950 So. 2d 1285 (Fla. Dist. Ct. App. 2007)

. . . . § 812.131(2)(b), Fla. Stat. (2005). . . . .

WALKER, v. STATE, 933 So. 2d 1236 (Fla. Dist. Ct. App. 2006)

. . . Section 812.131(1), Florida Statutes (2000), defines robbery by sudden snatching as follows: ‘Robbery . . .

THOMAS, v. STATE, 933 So. 2d 45 (Fla. Dist. Ct. App. 2006)

. . . A jury convicted Jermaine Thomas of robbery by snatching in violation of section 812.131(1), Florida . . . After being convicted of robbery by sudden snatching in violation of section 812.131(1), Florida Statutes . . . obbery by sudden snatching’ means the taking of money or other property from the victim’s person ....” § 812.131 . . .

NICHOLS, v. STATE, 927 So. 2d 90 (Fla. Dist. Ct. App. 2006)

. . . dismiss will support a conviction for “robbery by sudden snatching” as that offense is defined by section 812.131 . . . other property, when, in the course of the taking, the victim was or became aware of the taking.” § 812.131 . . .

S. COHEN, v. STATE, 920 So. 2d 682 (Fla. Dist. Ct. App. 2006)

. . . Cohen pleaded no contest to one count of robbery by sudden snatching in violation of section 812.131( . . .

SCOTT, v. STATE, 898 So. 2d 1213 (Fla. Dist. Ct. App. 2005)

. . . See § 812.131, Fla. Stat. (2001). We agree. . . .

T. N. v. STATE, 896 So. 2d 878 (Fla. Dist. Ct. App. 2005)

. . . a plea of no contest to the charge of robbery by sudden snatching, which is. prohibited by section 812.131 . . . Robbery by sudden snatching is prohibited by section 812.131, which provides: (1) “Robbery by sudden . . . Prior to the enactment of section 812.131, in order for a snatching to have constituted a robbery under . . . Compare § 812.131(2) with § 812.13(2). This case is analogous to Smith v. . . . Section 812.131 was enacted after Robinson was.decided, and it is comparable to the Georgia statute as . . .

UNITED STATES v. DAVIS,, 353 F. Supp. 2d 91 (D. Me. 2005)

. . . ROBBERY BY SUDDEN SNATCHING: FLORIDA STATUTE § 812.131 Mr. . . . .” § 812.131(l)(a),(b). A. . . . Stat. § 812.131(1). . . . Stat. § 812.131. . . . . . § 812.131(2)(a). There is no indication Mr. . . .

SMITH a k a v. STATE, 891 So. 2d 1133 (Fla. Dist. Ct. App. 2005)

. . . . § 812.131(1). Brown v. . . .

STATE v. FLOYD,, 872 So. 2d 445 (Fla. Dist. Ct. App. 2004)

. . . Section 812.131(1), Florida Statutes (2002), defines robbery by sudden snatching in pertinent part as . . .

STATE v. BURRIS,, 875 So. 2d 408 (Fla. 2004)

. . . In 2001, the Florida Legislature passed section 812.131, Florida Statutes (2001) (robbery by sudden snatching . . .

BROWN, v. STATE, 848 So. 2d 361 (Fla. Dist. Ct. App. 2003)

. . . This fact satisfies the statutory requirement of section 812.131, Florida Statutes, as it was a “continuous . . . series of acts or events.” § 812.131(3)(b)(emphasis supplied). . . . The state argues that the text of the robbery by sudden snatching statute, section 812.131(1) (“from . . . See § 812.131(1), Fla. . . . See § 812.131(l)(a) and (b) ("In order to satisfy this definition [of robbery by sudden snatching], it . . .

BURRIS, v. STATE, 825 So. 2d 1034 (Fla. Dist. Ct. App. 2002)

. . . . § 812.131, Fla. Stat. (2001). . . . .

In J. W. a v. LEITNER,, 801 So. 2d 295 (Fla. Dist. Ct. App. 2001)

. . . J.W. initially scored nine points on his RAI because he was charged with a violation of section 812.131 . . .

OWENS, Jr. v. STATE, 787 So. 2d 143 (Fla. Dist. Ct. App. 2001)

. . . The legislature abolished this requirement when it enacted section 812.131, Florida Statutes (1999), . . . Section 812.131 became effective on October 1, 1999. Ch. 99-175 § 3, at 974, Laws of Fla. . . .

SIMMONS, v. STATE, 780 So. 2d 263 (Fla. Dist. Ct. App. 2001)

. . . Although section 812.131, Florida Statutes, the section under which the Defendant was convicted, does . . .

SANDERS, v. STATE, 769 So. 2d 506 (Fla. Dist. Ct. App. 2000)

. . . See § 812.131, Fla. Slat. (1999); Ch. 99-175, § 1, Laws of Fla. . . .

HAYDON, v. STATE, 755 So. 2d 785 (Fla. Dist. Ct. App. 2000)

. . . case because of its effective date, the legislature has now made it clear, by the passage of section 812.131 . . .