## Facts

- Reid and an accomplice sought to recover money they believed was owed to them.
- They used force or threats against individuals to obtain money directly from those persons.
- The taking was not limited to reclaiming a specific, identifiable chattel previously transferred; it involved seizing money from a person through coercion.
- Reid was charged with robbery under New York law, which defines robbery as forcible stealing (larceny plus the use or threatened use of force).
- Reid requested a jury instruction on the “claim-of-right” theory, asserting he honestly believed he was entitled to the money and therefore lacked intent to steal.
- The trial court refused to submit a claim-of-right defense to the jury in the robbery case.
- Reid was convicted; the Appellate Division affirmed.
- The Court of Appeals reviewed the availability of claim of right in a robbery prosecution (in a single opinion addressing Reid and a companion case).

## Issues

1. Whether a defendant charged with robbery may assert a claim-of-right defense based on a good-faith belief of entitlement to the property taken.
2. Whether New York’s codification of claim of right in the larceny provisions implies its unavailability for robbery, where force against a person is an element.
3. Whether allowing claim of right in robbery would be consistent with the function of robbery law as protection against violence and intimidation.

## Decision

- The Court of Appeals affirmed Reid’s robbery conviction.
- The court held that claim of right is not a defense to robbery in New York.
- The trial court correctly refused to instruct the jury on claim of right.
- The use or threatened use of force to collect an alleged debt does not negate the “stealing” element of robbery.
- The court treated robbery as qualitatively different from non-forcible property offenses because it targets conduct that endangers personal security.

## Legal Principles

- Claim of right is a statutory defense codified for larceny, and it does not extend to robbery absent comparable legislative authorization.
- Robbery, as forcible stealing, is directed not only at wrongful taking of property but also at the coercive invasion of personal security created by force or intimidation.
- A good-faith belief that one is owed money does not authorize taking money from a person by force; private, self-help violence does not convert a forcible taking into a lawful recovery.
- When force is used against a person to obtain property, the law treats the conduct as robbery even if the actor asserts an entitlement to the property or debt repayment.
- Statutory structure may support a negative implication: the Legislature’s placement of a defense in one article (larceny) and omission from another (robbery) indicates a deliberate limitation.

## Conclusion

The Court of Appeals held that New York’s claim-of-right doctrine, though available for larceny, cannot be used to defend a robbery charge because robbery punishes forcible takings that threaten personal safety; a debtor’s belief that money is owed does not excuse using force to obtain it.


People v. Reid, 508 N.E.2d 661 (N.Y. 1987)