Ross Valore


This Note begins with an exploration of the factual circumstances that gave rise to the court’s determination that an objective standard should be applied when determining whether a threat of the immediate use of physical force exists in second-degree robbery cases. This Note then discusses the conflict among Missouri appellate courts regarding the determination of whether a threat of force exists, while also looking at how other states have handled this issue. Next, this Note provides an analysis of the Supreme Court of Missouri’s reasoning in Brooks and, finally, explores how the objective standard articulated by the court will be applied, along with a possible alternative solution to the conflict between stealing and robbery in bank theft cases.

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