What is the specific intent of an individual to steal in the context of a robbery statute?

MultiRegion, United States of America

The following excerpt is from United States v. Ornelas, 906 F.3d 1138 (9th Cir. 2018):

5 We recognize that this well-regarded treatise is not entirely consistent on this point. Another section of the treatise suggests that the specific intent to steal must coincide with the use or threatened use of force, but that section is unpersuasive because it relies only on a single modern case analyzing a state robbery statute. See 1 LaFave 6.3(a) & n.11 (citing People v. Green , 27 Cal.3d 1, 164 Cal.Rptr. 1, 609 P.2d 468, 498-500 (1980) ).

6 Indeed, even as to robbery statutes that, unlike 2112, require only general intent for the completed offense, we have required specific intent for an attempt. See, e.g. , United States v. Goldtooth , 754 F.3d 763, 770 (9th Cir. 2014) (requiring specific intent for attempted robbery within the special maritime and territorial jurisdiction of the United States under 18 U.S.C. 2111 ); United States v. Darby , 857 F.2d 623, 626 (9th Cir. 1988) (requiring specific intent for attempted bank robbery under 18 U.S.C. 2113(a) ).

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