In what circumstances will a defendant in a personal injury case successfully argue that snatching a wig off someone's head does not constitute robbery?

^11. In his reply brief, defendant asserts: "[T]he evidence did not demonstrate that the amount of force used to remove [C.S.]'s ponytail [wig], which was held only by hair clips, was equivalent to the degree of force that would be required to pull a strap off a handbag, which is held on with fasteners far stronger than hair clips." We may deem this argument forfeited because it was made first in the reply brief. (Neighbours v. Buzz Oates Enterprises (1990) 217 Cal.App.3d 325, 335, fn. 8.) In any event, defendant cites no authority for the proposition that snatching a wig off someone's head cannot constitute robbery unless it employs "the degree of force that would be required to pull a strap off a handbag."