Robbery

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A masked robber threatens a person with a gun Bundesarchiv Bild 102-12763, Bankuberfall.jpg
A masked robber threatens a person with a gun

Robbery is the crime of taking or attempting to take anything of value by force, threat of force, or by putting the victim in fear. According to common law, robbery is defined as taking the property of another, with the intent to permanently deprive the person of that property, by means of force or fear; that is, it is a larceny or theft accomplished by an assault. [1] Precise definitions of the offence may vary between jurisdictions. Robbery is differentiated from other forms of theft (such as burglary, shoplifting, pickpocketing, or car theft) by its inherently violent nature (a violent crime); whereas many lesser forms of theft are punished as misdemeanors, robbery is always a felony in jurisdictions that distinguish between the two. Under English law, most forms of theft are triable either way, whereas robbery is triable only on indictment. The word "rob" came via French from Late Latin words (e.g., deraubare) of Germanic origin, from Common Germanic raub -- "theft".

Crime unlawful act forbidden and punishable by criminal law

In ordinary language, a crime is an unlawful act punishable by a state or other authority. The term "crime" does not, in modern criminal law, have any simple and universally accepted definition, though statutory definitions have been provided for certain purposes. The most popular view is that crime is a category created by law; in other words, something is a crime if declared as such by the relevant and applicable law. One proposed definition is that a crime or offence is an act harmful not only to some individual but also to a community, society or the state. Such acts are forbidden and punishable by law.

Common law Law developed by judges

In law, common law is that body of law derived from judicial decisions of courts and similar tribunals. The defining characteristic of “common law” is that it arises as precedent. In cases where the parties disagree on what the law is, a common law court looks to past precedential decisions of relevant courts, and synthesizes the principles of those past cases as applicable to the current facts. If a similar dispute has been resolved in the past, the court is usually bound to follow the reasoning used in the prior decision. If, however, the court finds that the current dispute is fundamentally distinct from all previous cases, and legislative statutes are either silent or ambiguous on the question, judges have the authority and duty to resolve the issue. The court states an opinion that gives reasons for the decision, and those reasons agglomerate with past decisions as precedent to bind future judges and litigants. Common law, as the body of law made by judges, stands in contrast to and on equal footing with statutes which are adopted through the legislative process, and regulations which are promulgated by the executive branch. Stare decisis, the principle that cases should be decided according to consistent principled rules so that similar facts will yield similar results, lies at the heart of all common law systems.

Larceny is a crime involving the unlawful taking of the personal property of another person or business. It was an offence under the common law of England and became an offence in jurisdictions which incorporated the common law of England into their own law, where in many cases it remains in force.

Contents

Among the types of robbery are armed robbery, which involves the use of a weapon, and aggravated robbery, when someone brings with them a deadly weapon or something that appears to be a deadly weapon. Highway robbery or mugging takes place outside or in a public place such as a sidewalk, street, or parking lot. Carjacking is the act of stealing a car from a victim by force. Extortion is the threat to do something illegal, or the offer to not do something illegal, in the event that goods are not given, primarily using words instead of actions.

A weapon, arm or armament is any implement or device that can be used with intent to inflict damage or harm. Weapons are used to increase the efficacy and efficiency of activities such as hunting, crime, law enforcement, self-defense, and warfare. In broader context, weapons may be construed to include anything used to gain a tactical, strategic, material or mental advantage over an adversary or enemy target.

Carjacking is a robbery in which the item taken over is a motor vehicle.

Extortion criminal offense

Extortion is a criminal offense that consists in the obtainment of money, property, or services from an individual or institution, through coercion. It is sometimes euphemistically referred to as a "protection racket" since the racketeers often phrase their demands as payment for "protection" from threats from unspecified other parties; though often, and almost always, such "protection" is simply abstinence of harm from the same party, and such is implied in the "protection" offer. Extortion is commonly practiced by organized crime groups. The actual obtainment of money or property is not required to commit the offense, and making a threat of violence which refers to a requirement of a payment of money or property to halt future violence is sufficient to commit the offense. Exaction refers not only to extortion or the demanding and obtaining of something through force, but additionally, in its formal definition, means the infliction of something such as pain and suffering or making somebody endure something unpleasant.

Criminal slang for robbery includes "blagging" (armed robbery, usually of a bank) or "stick-up" (derived from the verbal command to robbery targets to raise their hands in the air), and "steaming" (organized robbery on underground train systems).

In UK slang, steaming is a robbery performed on train or bus passengers by a gang or large group and often involving some level of violence. It is often used interchangeably with mugging, referring to a specific subcategory of that crime. Several cases have been reported on the London Underground and other city public transport systems although not exclusively localised to them. It may also be applied to other theft such as shoplifting, involving a large group employing distraction tactics, intimidation or actual violence against staff. In general, the term refers to the operation in a large group and the use of intimidation and violence to commit theft.

Canada

In Canada, the Criminal Code makes robbery an indictable offence, subject to a maximum penalty of life imprisonment. If the accused uses a restricted or prohibited firearm to commit robbery, there is a mandatory minimum sentence of five years for the first offence, and seven years for subsequent offences. [2]

<i>Criminal Code</i> (Canada)

The Criminal Code is a law that codifies most criminal offences and procedures in Canada. Its official long title is "An Act respecting the criminal law". Section 91(27) of the Constitution Act, 1867 establishes the sole jurisdiction of Parliament over criminal law in Canada.

In many common law jurisdictions, an indictable offence is an offence which can only be tried on an indictment after a preliminary hearing to determine whether there is a prima facie case to answer or by a grand jury. In the United States, a crime of similar severity and rules is called a felony, which also requires an indictment.

Life imprisonment in Canada is a criminal sentence for certain offences that has an indeterminate length and is the most severe punishment for any crime in the country. Criminal laws allowing for life imprisonment are enacted by the Parliament of Canada and apply uniformly across the country, as federal law applies to prison terms of 2 years or longer. Sentences of 2 years or less are to be served in provincial prisons.

Republic of Ireland

Robbery is a statutory offence in the Republic of Ireland. It is created by section 14(1) of the Criminal Justice (Theft and Fraud Offences) Act, 2001, which provides:

Republic of Ireland Country in Europe on the island of Ireland

Ireland, also known as the Republic of Ireland, is a country in north-western Europe occupying 26 of 32 counties of the island of Ireland. The capital and largest city is Dublin, which is located on the eastern side of the island. Around a third of the country's population of 4.8 million people resides in the greater Dublin area. The sovereign state shares its only land border with Northern Ireland, a part of the United Kingdom. It is otherwise surrounded by the Atlantic Ocean, with the Celtic Sea to the south, St George's Channel to the south-east, and the Irish Sea to the east. It is a unitary, parliamentary republic. The legislature, the Oireachtas, consists of a lower house, Dáil Éireann, an upper house, Seanad Éireann, and an elected President who serves as the largely ceremonial head of state, but with some important powers and duties. The head of government is the Taoiseach, who is elected by the Dáil and appointed by the President; the Taoiseach in turn appoints other government ministers.

The Criminal Justice Act, 2001 updates and consolidates the law relating to dishonesty and fraud in the Republic of Ireland.

A person is guilty of robbery if he or she steals, and immediately before or at the time of doing so, and in order to do so, uses force on any person or puts or seeks to put any person in fear of being then and there subjected to force. [3]

United Kingdom

England and Wales

Robbery is a statutory offence in England and Wales. [4] It is created by section 8(1) of the Theft Act 1968 which reads:

A person is guilty of robbery if he steals, and immediately before or at the time of doing so, and in order to do so, he uses force on any person or puts or seeks to put any person in fear of being then and there subjected to force. [5]

Aggravated theft

Robbery is the only offence of aggravated theft. [6]

Aggravated robbery

There are no offences of aggravated robbery. [6]

Steals

This requires evidence to show a theft as set out in section 1(1) of the Theft Act 1968. In R v Robinson [7] the defendant threatened the victim with a knife in order to recover money which he was actually owed. His conviction for robbery was quashed on the basis that Robinson had an honest, although unreasonable, belief (under Section 2(1)(a) of the Act) in his legal right to the money. See also R v Skivington [1968] 1 QB 166, [1967] 2 WLR 655, 131 JP 265, 111 SJ 72, [1967] 1 All ER 483, 51 Cr App R 167, CA.

In R v Hale (1978) [8] the application of force and the stealing took place in different locations, and it was not possible to establish the timing; it was held that the appropriation necessary to prove theft was a continuing act, and the jury could correctly convict of robbery; this approach was followed in R v Lockley (1995) [9] when the force was applied to a shopkeeper after property had been taken. It was argued that the theft should be regarded as complete by this time, and R v Gomez (1993), [10] should apply; the court disagreed, preferring to follow R v Hale.

Actual or threatened force against a person

The threat or use of force must take place immediately before or at the time of the theft. Force used after the theft is complete will not turn the theft into a robbery.

The words "or immediately after" that appeared in section 23(1)(b) of the Larceny Act 1916 were deliberately omitted from section 8(1). [11]

The book "Archbold" said that the facts in R v Harman, [12] which did not amount to robbery in 1620, would not amount to robbery now. [13]

It was held in R v Dawson and James (1978) [14] that "force" is an ordinary English word and its meaning should be left to the jury. This approach was confirmed in R v Clouden (1985) [15] and Corcoran v Anderton (1980), [16] both handbag-snatching cases. Stealing may involve a young child who is not aware that taking other persons' property is not in order.

Threat

The victim must be placed in apprehension or fear that force would be used immediately before or at the time of the taking of the property. A threat is not immediate if the wrongdoer threatens to use force of violence some future time.

Robbery occurs if an aggressor forcibly snatched a mobile phone or if they used a knife to make an implied threat of violence to the holder and then took the phone. The person being threatened does not need to be the owner of the property. It is not necessary that the victim was actually frightened, but the defendant must have put or sought to put the victim or some other person in fear of immediate force. [17]

The force or threat may be directed against a third party, for example a customer in a jeweller's shop. [18] Theft accompanied by a threat to damage property will not constitute robbery, but it may disclose an offence of blackmail.

Dishonestly dealing with property stolen during a robbery will constitute an offence of handling.

Mode of trial

Robbery is an indictable-only offence. [19]

Sentence

Marauders attacking a group of travellers, by Jacques Courtois Courtois.jpg
Marauders attacking a group of travellers, by Jacques Courtois

Under current sentencing guidelines, the punishment for robbery is affected by a variety of aggravating and mitigating factors. Particularly important is how much harm was caused to the victim and how much culpability the offender had (e.g. carrying a weapon or leading a group effort implies high culpability). Robbery is divided into three categories which are, in increasing order of seriousness: street or less sophisticated commercial; dwelling; and professionally-planned commercial. [20]

Robbery generally results in a custodial sentence. Only a low-harm, low-culpability robbery with other mitigating factors would result in an alternative punishment, in the form of a high level community order. [20] The maximum legal punishment is imprisonment for life. [21] It is also subject to the mandatory sentencing regime under the Criminal Justice Act 2003. Current sentencing guidelines advise that the sentence should be no longer than 20 years, for a high-harm, high-culpability robbery with other aggravating factors.

The "starting point" sentences are:

  • Low-harm, low-culpability street robbery: 1 year
  • Medium-harm, medium-culpability street robbery: 4 years
  • Medium-harm, medium-culpability professionally-planned robbery: 5 years
  • High-harm, high-culpability street robbery: 8 years
  • High-harm, high-culpability professionally-planned robbery: 16 years [20]

An offender may also serve a longer sentence if they are convicted of other offences alongside the robbery, such as assault and grievous bodily harm.

History

"The Eveleigh Payroll Heist", 1914 was committed in the middle of the day in a busy area and has been reported to be the first robbery in Australia where a getaway car was used. Robbery Under Arms The Eveleigh Payroll Heist, 1914 (6151815914) (6).jpg
"The Eveleigh Payroll Heist", 1914 was committed in the middle of the day in a busy area and has been reported to be the first robbery in Australia where a getaway car was used.
Common law

Robbery was an offence under the common law of England. Matthew Hale provided the following definition:

Robbery is the felonious and violent taking of any money or goods from the person of another, putting him in fear, be the value thereof above or under one shilling. [22]

See the statutes 23 Hen 8 c 1 and 5 & 6 Edw 6 c 9 as to benefit of clergy. And also 25 Hen 8 c 3 and 1 Edw 6 c 12. And also 29 Eliz c 15 and 3 & 4 W & M c 9.

The common law offence of robbery was abolished for all purposes not relating to offences committed before 1 January 1969 [23] by section 32(1)(a) of the Theft Act 1968.

Statute

See sections 40 to 43 of the Larceny Act 1861.

Section 23 of the Larceny Act 1916 read:

23.-(1) Every person who -

(a) being armed with any offensive weapon or instrument, or being together with one other person or more, robs, or assaults with intent to rob, any person;
(b) robs any person and, at the time of or immediately before or immediately after such robbery, uses any personal violence to any person;

shall be guilty of felony and on conviction thereof liable to penal servitude for life, and, in addition, if a male, to be once privately whipped.

(2) Every person who robs any person shall be guilty of felony and on conviction thereof liable to penal servitude for any term not exceeding fourteen years.

(3) Every person who assaults any person with intent to rob shall be guilty of felony and on conviction thereof liable to penal servitude for any term not exceeding five years.

This section provided maximum penalties for a number of offences of robbery and aggravated robbery. [6]

The following cases relate to the use of force:

  • R v Lapier (1784) 1 Leach 320
  • R v Moore (1784) 1 Leach 335
  • R v Davies (1803) 2 East PC 709
  • R v Mason (1820) R & R 419
  • R v Gnosil (1824) 1 C & P 304
  • R v Walls and Hughes (1845) 2 C & K 214

Assault with intent to rob

If a robbery is foiled before it can be completed, an alternative offence (with the same penalty, given by section 8(2) of the 1968 Act) is assault; any act which intentionally or recklessly causes another to fear the immediate and unlawful use of force, with an intent to rob, will suffice.

The following cases are relevant:

  • R v Trusty and Howard (1783) 1 East PC 418
  • R v Sharwin (1785) 1 East PC 421
Mode of trial and sentence

Assault with intent to rob is an indictable-only offence. [19] It is punishable with imprisonment for life or for any shorter term. [24]

Assault with intent to rob is also subject to the mandatory sentencing regime under the Criminal Justice Act 2003.

Northern Ireland

Robbery is a statutory offence in Northern Ireland. It is created by section 8 of the Theft Act (Northern Ireland) 1969.

United States

In the United States, robbery is generally treated as an aggravated form of common law larceny. Specific elements and definitions differ from state to state. The common elements of robbery are:

  1. a trespassory
  2. taking and
  3. carrying away
  4. of the personal property
  5. of another
  6. with the intent to steal
  7. from the person or presence of the victim
  8. by force or threat of force. [25]

The first six elements are the same as common law larceny. It is the last two elements that aggravate the crime to common law robbery.

from the person or presence of the victim – robbery requires that the property be taken directly from the person of the victim or from their presence. This is different from larceny which simply requires that property be taken from the victim's possession, actual or constructive. Property is "on the victim's person" if the victim is actually holding the property, or the property is contained within clothing the victim is wearing or is attached to a victim's body such as a watch or earrings. [26] Property is in a person's presence when it is within the area of their immediate control. The property has to be close enough to the victim's person that the victim could have prevented its taking if he/she had not been placed in fear or intimidation. [26]

by force or threat of force – the use of force or threat of force is the defining element of robbery. For there to be robbery there must be "force or fear" in perpetrating the theft. [27] Questions concerning the degree of force necessary for robbery have been the subject of much litigation. Merely snatching the property from the victim's person is not sufficient force unless the victim resists or one of the items is attached or carried in such a way that a significant amount of force must be used to free the item from the victim's person.[ citation needed ]

For robbery the victim must be placed in "fear" of immediate harm by threat or intimidation. The threat need not be directed at the victim personally. Threats to third parties are sufficient. The threat must be one of present rather than future personal harm. Fear does not mean "fright", [26] it means apprehension – an awareness of the danger of immediate bodily harm.

California

The maximum sentence for robbery in California is 9 years, according to Penal Code section 213(a)(1)(A). [28]

The threat or use of force does not have to take place immediately before or at the time of the theft. [29] Force used after the theft will turn the theft into a robbery unless the theft is complete. The theft is considered completed when the perpetrator reaches a place of temporary safety with the property. [30]

Robbery statistics

Robberies, by country

The United Nations Office on Drugs and Crime notes "that when using the figures, any cross-national comparisons should be conducted with caution because of the differences that exist between the legal definitions of offences in countries, or the different methods of offence counting and recording". Also not every single crime is reported, meaning two things; (1) robbery rates are going to appear lower than they actually are and; (2) the percentage of crime that is not reported is going to be higher in some countries then others, for example – in one country 86% of the robberies were reported, whereas in another country only 67% of the robberies were reported. The last thing to note is that crime will vary by certain neighborhoods or areas in each country, so, just because a nationwide rate is a specified rate, does not mean that everywhere in that country retains the same amount of danger or safety.

Homicides during a robbery, by country

Robberies have been depicted, sometimes graphically, in various forms of media, and several robbers have become pop icons, such as Bonnie and Clyde and John Dillinger. Examples of media works focused on robberies include:

In film

In literature

In video games

Video games Payday: The Heist and Payday 2 are both games by Overkill Software where one of the main objectives is to steal items of monetary value at places such as banks, art galleries, armored trucks, and more. [37]

See also

Related Research Articles

An assault is the act of inflicting physical harm or unwanted physical contact upon a person or, in some specific legal definitions, a threat or attempt to commit such an action. It is both a crime and a tort and, therefore, may result in either criminal and/or civil liability. Generally, the common law definition is the same in criminal and tort law.

Theft Act of taking anothers property without permission or consent

In common usage, theft is the taking of another person's property or services without that person's permission or consent with the intent to deprive the rightful owner of it. The word is also used as an informal shorthand term for some crimes against property, such as burglary, embezzlement, larceny, looting, robbery, shoplifting, library theft, and fraud. In some jurisdictions, theft is considered to be synonymous with larceny; in others, theft has replaced larceny. Someone who carries out an act of or makes a career of theft is known as a thief. The act of theft is also known by other terms such as stealing, thieving, and filching.

Burglary Crime of entering someones property, often with the intent to steal from them or commit another offence

Burglary, also called breaking and entering and sometimes housebreaking, is an unlawful entry into a building or other location for the purposes of committing an offence. Usually that offence is theft, but most jurisdictions include others within the ambit of burglary. To engage in the act of burglary is to burgle in British English, a term back-formed from the word burglar, or to burglarize in American English.

Blackmail is an act of coercion using the threat of revealing or publicizing either substantially true or false, and often damaging, information about a person, to the public, family members, or associates unless certain demands are met. It may involve using threats of physical, mental or emotional harm, or of criminal prosecution, against the victim or someone close to the victim. It is normally carried out for personal gain, most commonly of position, money, or property.

In criminal law, property is obtained by false pretenses when the acquisition results from intentional misrepresenting of a past or existing fact.

Battery is a criminal offense involving unlawful physical contact, distinct from assault which is the act of creating apprehension of such contact.

Theft Act 1968 United Kingdom legislation

The Theft Act 1968 is an Act of the Parliament of the United Kingdom. It creates a number of offences against property in England and Wales. On 15 January 2007 the Fraud Act 2006 came into force, redefining most of the offences of deception.

In England, Wales and Northern Ireland taking without owner's consent (TWOC), also referred to as unauthorised taking of a motor vehicle (UTMV) describes any unauthorised use of a car or other conveyance that does not constitute theft. A similar offence, known as taking and driving away, also exists in Scotland.

Common assault was an offence under the common law of England, and has been held now to be a statutory offence in England and Wales. It is committed by a person who causes another person to apprehend the immediate use of unlawful violence by the defendant. It was thought to include battery but it does not. In England and Wales, the penalty and mode of trial for this offence is now provided section 39 of the Criminal Justice Act 1988, and it has been held that the offence should be alleged as contrary to the statute because of this. It was also held that common assault and battery are two distinct offences, so that a charge that the accused "assaulted and battered" another person would be bad for duplicity.

Murder is an offence under the common law of England and Wales. It is considered the most serious form of homicide, in which one person kills another with the intention to cause either death or serious injury unlawfully. The element of intentionality was originally termed malice aforethought although it required neither malice nor premeditation.

Property crime is a category of crime that includes, among other crimes, burglary, larceny, theft, motor vehicle theft, arson, shoplifting, and vandalism. Property crime is a crime to obtain money, property, or some other benefit. This may involve force, or the threat of force, in cases like robbery or extortion. Since these crimes are committed in order to enrich the perpetrator they are considered property crimes. Crimes against property are divided into two groups: destroyed property and stolen property. When property is destroyed, it could be called arson or vandalism. Examples of the act of stealing property is robbery or embezzlement.

Penal Code (Singapore) Criminal code of Singapore

The Penal Code of Singapore sets out general principles of the criminal law of Singapore, as well as the elements and penalties of common criminal offences such as homicide, theft and cheating. The Penal Code does not exhaustively define all the criminal offences applicable in Singapore – a large number of these are created by other statutes such as the Arms Offences Act, Kidnapping Act, Misuse of Drugs Act and Vandalism Act.

Crimes Act 1900

The Crimes Act 1900, is a New South Wales statute that sets out the majority of criminal offences for the state of New South Wales in Australia. Along with the Crimes Act 1914, and the Federal Criminal Code Act 1995, these two pieces of legislation form the majority of criminal law for New South Wales.

English criminal law

English criminal law concerns offences, their prevention and the consequences, in England and Wales. Criminal conduct is considered to be a wrong against the whole of a community, rather than just the private individuals affected. The state, in addition to certain international organisations, has responsibility for crime prevention, for bringing the culprits to justice, and for dealing with convicted offenders. The police, the criminal courts and prisons are all publicly funded services, though the main focus of criminal law concerns the role of the courts, how they apply criminal statutes and common law, and why some forms of behaviour are considered criminal. The fundamentals of a crime are a guilty act and a guilty mental state. The traditional view is that moral culpability requires that a defendant should have recognised or intended that they were acting wrongly, although in modern regulation a large number of offences relating to road traffic, environmental damage, financial services and corporations, create strict liability that can be proven simply by the guilty act.

Burglary is a statutory offence in England and Wales.

Larceny Act 1916 United Kingdom legislation

The Larceny Act 1916 was an Act of the Parliament of the United Kingdom. Its purpose was to consolidate and simplify the law relating to larceny triable on indictment and to kindred offences.

Non-fatal offences against the person, under English law, are generally taken to mean offences which take the form of an attack directed at another person, that do not result in the death of any person. Such offences where death occurs are considered homicide, whilst sexual offences are generally considered separately, since they differ substantially from other offences against the person in theoretical basis and composition. Non-fatal offences against the person mainly derive from the Offences against the Person Act 1861, although no definition of assault or battery is given there.

References

  1. "Carter, Floyd J. vs U.S." June 12, 2000. Archived from the original on September 3, 2006. Retrieved 2008-05-04.
  2. Criminal Code, RSC 1985, c C-46, ss 343, 344.
  3. Digitised copy of section 14 of the Criminal Justice (Theft and Fraud Offences) Act, 2001. From the Office of the Attorney General.
  4. The extent of section 8 of the Theft Act 1968 is provided by section 36(3) of that Act.
  5. Digitised copy of section 8 of the Theft Act 1968, from Legislation.gov.uk.
  6. 1 2 3 Griew, Edward. The Theft Acts 1968 and 1978. Sweet and Maxwell. Fifth Edition. 1986. Paragraph 3-01 at page 79.
  7. R v Robinson [1977] Crim LR 173, CA
  8. R v Hale (1978) 68 Cr App R 415, [1979] Crim LR 596, CA
  9. Crim LR 656
  10. [1993] AC 442, House of Lords
  11. The Criminal Law Revision Committee. Eighth Report. Theft and Related Offences. 1966. Cmnd 2977. Paragraph 65.
  12. R v Harman (1620) 1 Hale 534, (1620) 2 Rolle 154, (1620) 81 ER 721
  13. Archbold Criminal Pleading, Evidence and Practice, 1999, para. 21-99 at p. 1772
  14. R v Dawson and James (1978) 68 Cr App R 170, CA
  15. R v Clouden, unreported (C.A. No. 3897, 4 February 1985). For details see Griew, Edward. The Theft Acts 1968 and 1978. Fifth Edition. Sweet and Maxwell. 1986. Paragraphs 3-04 and 3-05 at page 80.
  16. Corcoran v Anderton (1980) 71 Cr App R 104, [1980] Crim LR 385, DC
  17. R v Khan LTL (9 April 2001) and Archbold 2006 21-101.
  18. Smith v Desmond [1965] HL
  19. 1 2 This is the effect of section 8(2) of the Theft Act 1968 and paragraph 28(a) of Schedule 1 to the Magistrates' Courts Act 1980.
  20. 1 2 3 "Sentencing Council" (PDF). Sentencing Council - Robbery: Defintive guidelines. Retrieved 2018-05-18.
  21. The Theft Act 1968, section 8(2)
  22. 1 Hale 532
  23. The Theft Act 1968, section 35(1)
  24. The Theft Act 1968, section 8(2)
  25. Lafave, Criminal Law 3rd ed. (West 2000) Sec. 8.11
  26. 1 2 3 Lafave, Criminal Law 3rd ed. (West 2000) Sec 8.11
  27. Lafave, Criminal Law 3rd ed. (West 2000) Sec 8.11;Boyce & Perkins, Criminal Law, 3rd ed. (1992)
  28. "CALIFORNIA PENAL CODE SECTION 211-215". Archived from the original on 2012-10-23. Retrieved 2012-09-21.
  29. People v. Gomez (2008) 43 Cal.4th 249, 254.
  30. People v. Flynn (2000) 77 Cal.App.4th 766, 772, 91 Cal.Rptr.2d 902.
  31. Crime and criminal justice statistics, used table: robbery. Retrieved May-24-2014
  32. UNODC Homicide Statistics 2013, used two tables: Homicide counts and rates, time series 2000–2012 & Homicide victims killed during robbery as percentage of total homicide victims, time series 2005–2012. Retrieved May-24-2014
  33. 1 2 Piero Colaprico (13 May 2013). "Milano, è morto Luciano Lutring: lo chiamavano 'il solista del mitra'". La Repubblica . Retrieved 13 May 2013.
  34. "Morto Luciano Lutring, l'ex bandito divenuto scrittore e artista" (in Italian). Retrieved 2016-09-19.
  35. White, Lionel (1955). Clean Break (First ed.). Dutton. p. 189. ASIN   B0000CJAQV.
  36. Weiler, A.H. (May 21, 1956). "Movie Review: The Killing (1956); SCREEN: 'The Killing'; New Film at the Mayfair Concerns a Robbery". The New York Times.
  37. "OVERKILL Software".

Further reading