containing a general statement about force or the threat of force being the difference between robbery and theft without analyzing or applying the Workman test
How later courts described this case
- containing a general statement about force or the threat of force being the difference between robbery and theft without analyzing or applying the Workman test
- “Indeed, without the implicit threat to use force, it is difficult to imagine why the teller would comply with the note’s demand for money.”
- bank robber implied a threat by handing a note asking for money, but not stating a threat
Written by the judges who cited it.
The opinion
Madsen, C.J.
¶56 (concurring) I agree with the lead opinion that there was sufficient evidence to find an implied threat of force and to support Charles Farnsworth’s conviction based on accomplice liability. I write separately because I agree with the dissent’s conclusion that the plea agreement should have been admitted into evidence and failure to do so amounted to constitutional error. However, because I would hold that the error was harmless beyond a reasonable doubt, I concur in the lead opinion.