Threats of Immediate Force to be Judged on Totality of the Circumstances to Prove Robbery

In People v Villanueva, 2017 NY Slip Op 01299, the First Department affirmed the defendant’s conviction for Robbery in the Second Degree even though the threat of force was to be inflicted by another party in the future should the victim refuse to comply. In Villanueva, the defendant – Carolina Villanueva – was arrested and charged with her co-defendant Ruby

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