## Facts

- Ray Patton was indicted for robbery and theft from the person based on a single purse-snatching incident in Peoria Heights.
- Rita Alexander walked with her family to a church service carrying her purse “in the fingertips” of her left hand at her side.
- Patton approached alongside her and swiftly grabbed the purse and fled.
- Alexander testified the grab threw her arm back “a little bit,” and the purse was gone before she realized what occurred.
- After a brief shock, Alexander screamed and her husband chased Patton unsuccessfully; Patton was later identified and apprehended.
- No evidence showed threats, injury, resistance, or any additional force beyond the taking itself.

## Issues

1. Whether snatching a purse from a victim’s hand, causing only slight incidental movement and no injury, resistance, or threat, constitutes the “use of force” (or threat of imminent force) required for robbery under Illinois law.
2. Whether the evidence supported only theft from the person rather than robbery.

## Decision

- The Illinois Supreme Court affirmed the appellate court’s judgment.
- The court held the evidence was insufficient to prove robbery because the taking involved no qualifying force or threat.
- The proper conviction on these facts was theft from the person, and the case was to proceed consistent with entering judgment on that lesser offense.

## Legal Principles

- Illinois robbery requires a taking from the person or presence of another by the use of force or by threatening the imminent use of force.
- Theft from the person requires an unauthorized taking from the person but does not require force or threats.
- Minimal contact incidental to removing property from a victim’s grasp, without evidence of resistance, injury, fear, or coercive force, does not satisfy robbery’s force element.
- When the force/threat element fails but an unauthorized taking from the person is proven, theft from the person is the appropriate lesser offense.

## Conclusion

Because the record showed only a swift snatching that caused slight incidental movement and no resistance, injury, or threat, the evidence did not establish the force or threat required for robbery; it supported conviction only for theft from the person.


People v. Patton, 389 N.E.2d 1174 (Ill. 1979)