People v. Williams, 491 Mich. 164

Gas station robbery: defendant claimed gun and obtained cash (~$160).
Tobacco-store incident: defendant threatened clerk with hand under coat; clerk did not hand over money.
Defendant pled guilty to armed robbery in both cases; plea in tobacco store case relied on factual basis for attempted larceny.
Post-plea, defense moved to withdraw pleas arguing no completed larceny; court held 2004 amendments allow conviction on attempted larceny.
Court of Appeals affirmed; majority held amendments broaden robbery to include attempts; dissent argued completed larceny still required.
Court granted leave to determine if completed larceny is required and analyzed statutory language de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 2004 amendment remove completed larceny as an element?	State argues amendments include attempted larceny.	Williams argues only completed larceny supports robbery.	Yes, amendments remove completed larceny requirement.
Does phrase 'in the course of committing a larceny' include attempts?	State contends it includes attempts.	Williams contends it excludes attempts.	Yes, it includes attempts.
Does this interpretation abolish the distinction between armed robbery and assault with intent to rob?	State preserves distinct offenses via statutory change.	Williams would merge offenses.	Legislature expanded robbery, but completed larceny remains in armed robbery (preserves distinction).

People v Covelesky, 217 Mich 90 (1921) (definition/history of robbery and larceny in Michigan)
People v Randolph, 466 Mich 532 (2002) (transactional approach rejected; force before or during taking must occur)
People v Cobbs, 443 Mich 276 (1993) (Cobbs framework for Cobb/plea procedures and sentencing)