The People, Plaintiff and Respondent v. Demetrius Lamont Williams, Defendant and Appellant — Baxter, J., Dissenting

Summary

Justice Baxter, dissenting, would hold that theft by false pretenses can become robbery when the defendant uses force or fear to retain the property or escape before reaching a place of safety. The dissent relies on California's unified theft statutes, the continuing nature of robbery, and the statutory focus on force or fear used against persons during the carrying away of property. Baxter would affirm the Court of Appeal's judgment, contrary to the majority's conclusion that theft by false pretenses ends when title passes.