People v. Anderson, 51 Cal. 4th 989

Anderson, a long-term methamphetamine addict with no prior history of violence, robbed by forcibly taking Pamela Thompson's car.
He drove the stolen car toward an exit gate, attempting to clear the gate as Pamela cried out and was fatally struck during the escape.
Anderson claimed the fatal driving was accidental and that his intent was to steal and escape, not to harm or intimidate Pamela.
He was convicted of first degree felony murder with a robbery special circumstance, robbery, and receipt of stolen property after a jury trial.
The Court of Appeal reversed, holding the trial court erred by failing to give a sua sponte instruction on accident as a defense to robbery.
The Supreme Court granted review and reversed the Court of Appeal, agreeing that accident is not a mandatory sua sponte instruction when the mental-element instructions are complete and correct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does robbery require an intent to use force or fear, or only forceful taking with intent to steal?	Anderson argued robbery requires intent to harm or fear the victim.	Anderson contended there is an unidentified element requiring intent to cause fear or force against the victim.	Robbery does not require an element to intend to frighten; it suffices that the forcible act was motivated by the intent to steal.
Is accident a defense to robbery that warrants sua sponte instruction by the trial court?	The People argued no automatic instruction; the defense was not a mandatory sua sponte issue.	Anderson asserted trial court should instruct on accident to negate the mental element.	No, trial courts are not obligated to give accident instructions sua sponte; such instructions are only required upon defense request when relevant to negate the mental element.
If accident is not a mandatory defense, could the lack of an instruction on general intent to use force prejudice the defendant?	Not necessary since the general intent element is not required for robbery as held by the majority.	Lack of general-intent instructions could prejudice the defense by misdirecting the jury.	Not prejudicial under Neder v. United States standard because the record shows substantial evidence supporting the general intent to use force and the absence of error could not have changed the result.

People v. Bolden, 29 Cal.4th 515 (2002) (robbery elements and timing of force)
People v. Gomez, 43 Cal.4th 249 (2008) (robbery as taking from person or presence with force or fear)
People v. Estes, 147 Cal.App.3d 23 (1983) (post-taking force to retain property; continuing offense)
People v. Green, 27 Cal.3d 1 (1980) (force or fear as element of robbery; intent to steal)
People v. Morales, 49 Cal.App.3d 134 (1975) (excessive force beyond mere taking)
People v. Burns, 172 Cal.App.4th 1251 (2009) (legal standard for force beyond initial taking)
People v. Williams, 26 Cal.4th 779 (2001) (mental element for assault and related standards)
People v. Colantuono, 7 Cal.4th 206 (1994) (assault requires general intent to commit violence)
People v. Jennings, 50 Cal.4th 616 (2010) (misfortune/accident tied to mental state elements)
People v. Acosta, 45 Cal.2d 538 (1955) (accident defense negating mental state element)
People v. Lara, 44 Cal.App.4th 102 (1996) (accident defense available to negate intent in battery)
People v. Jones, 234 Cal.App.3d 1303 (1991) (accident defense in attempted murder when discharge not intended)
People v. Gonzales, 74 Cal.App.4th 382 (1999) (accident defense to negate mental element in crime)
People v. Roldan, 35 Cal.4th 646 (2005) (pinpoint accident instructions when defense raised)