People v. Webster
Supreme Court of California
814 P.2d 1273 (1991)
Larry Webster (defendant), leader of a homeless encampment, arranged to borrow William Burke's car under the pretense of a joint outing, but actually planned to lure Burke to the group's camp, kill him, and steal his car to flee the area after other members' earlier robbery drew police attention. Webster stabbed Burke to death at the camp, and the group then walked back to Burke's parked car, loaded it, and drove off before being stopped for speeding; Webster was convicted of first-degree murder with special circumstances including robbery and sentenced to death, and argued on automatic appeal that the evidence didn't support the robbery finding since Burke's car wasn't taken from his immediate presence by force.
Whether a theft amounts to robbery when the defendant, intending to rob the victim, first moves the victim away from the property by peaceful means and then uses force or fear to complete the taking.