STATE OF MISSOURI, Plaintiff-Respondent v. LEIGHTON MICHAEL QUAPAW, SD36693

Overnight cashier at Big Daddy’s C-Store in Seneca refused Defendant’s purchase after his card was denied; Defendant left and returned about ten minutes later armed with a knife.
Defendant approached the cashier, demanded money, tried to stab her, and told her to give him $20 to go away.
Victim hit the register’s drawer-open button, took $20 from the drawer, and handed it to Defendant; Defendant fled with the cash.
Defendant was charged with first-degree robbery and armed criminal action; jury acquitted on those charges but convicted of the lesser-included offense of stealing.
The jury found Defendant had “physically take[n]” the money from the victim, elevating stealing to a class D felony; Defendant appealed claiming insufficiency of evidence that he “physically” took the money.
The court reviewed sufficiency under the standard that accepts the evidence and reasonable inferences supporting the verdict and affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to show Defendant "physically takes" property from victim for felony stealing	State: Coercion and hand-to-hand transfer from the victim satisfies the statutory element; evidence supports conviction	Quapaw: "Physically takes" means a forceful/rough taking; a handover by the victim is not a physical taking, so element not proven	Court: Rejected narrow reading; taking from the person includes receipt from victim’s hand under coercion; evidence sufficient; conviction affirmed

State v. Naylor, 510 S.W.3d 855 (Mo. banc 2017) (standard for sufficiency review)
State v. Letica, 356 S.W.3d 157 (Mo. banc 2011) (sufficiency review principles)
State v. Diaz, 611 S.W.3d 373 (Mo. App. S.D. 2020) (appellate sufficiency discussion)
State v. Branyon, 939 S.W.2d 921 (Mo. App. E.D. 1996) (holding taking from victim’s hand satisfies "from the person")
State v. Cascone, 648 S.W.2d 190 (Mo. App. W.D. 1983) (physical taking found where money taken from victim’s pocket or handed and picked up)