## Facts

- Paul D. Anderson, a longtime methamphetamine addict, went to an apartment complex intending to steal a car.
- Nineteen-year-old Pamela Thompson parked her car in the complex’s carport and went to her apartment.
- Anderson entered Thompson’s car using a shaved key, started it, and attempted to drive out through a gated exit.
- When the gate did not open automatically, Anderson repositioned the car and then accelerated to exit as another car triggered the gate.
- Thompson, looking for her missing car, was walking near the gate area; Anderson struck and killed her while fleeing with the car.
- Anderson claimed the collision was accidental and that he did not intend to hit, injure, or frighten Thompson.
- A jury convicted Anderson of first degree felony murder (based on robbery), robbery, and receiving stolen property, and found true a robbery-murder special circumstance.
- The Court of Appeal reversed, reasoning the trial court should have instructed sua sponte on accident as a defense to robbery.
- The California Supreme Court granted review.

## Issues

1. Whether robbery requires, in addition to intent to steal, a separate intent to apply force or to cause the victim to experience fear.
2. Whether a trial court must instruct sua sponte on accident as a defense to robbery when the defendant’s accident theory functions only to deny the mens rea of the charged offense.

## Decision

- The California Supreme Court reversed the Court of Appeal and reinstated the judgment.
- The court held robbery does not require intent to apply force or to cause fear; it is enough that the defendant intended to steal and committed a forcible act in furtherance of that theft.
- The court held no sua sponte accident instruction was required because the accident claim merely attempted to negate the intent element already covered by the standard instructions on robbery.
- Because the robbery conviction stood, the felony-murder conviction and robbery-murder special-circumstance finding were also sustained.

## Legal Principles

- California robbery requires an intent to steal and a taking accomplished by force or fear; it does not require a separate intent to use force or to frighten the victim.
- A defendant commits robbery if, motivated by an intent to steal, the defendant commits a forcible act against the victim during the taking or asportation, even if the defendant did not intend the victim to experience force or fear.
- A trial court has no sua sponte duty to instruct on accident when the “accident” theory only disputes whether the defendant formed the mens rea required for the offense and the jury is otherwise properly instructed on that mens rea.

## Conclusion

The court clarified that robbery’s mental-state requirement is the intent to steal, not an added intent to apply force or induce fear, and it limited sua sponte accident instructions to situations where accident operates as more than a denial of the charged crime’s required intent.


People v. Anderson, 51 Cal. 4th 989, 252 P.3d 968 (Cal. 2011)