State of Missouri v. Gary Leland Coleman, 463 S.W.3d 353

In Oct 2012 Gary Coleman entered a bank, placed a plastic grocery sack on the counter, and told the teller, “I need you to do me a favor. Put the money in this bag.”
Teller placed $1,472 in the bag; an assistant manager approached and Coleman told her not to move farther; Coleman then took the bag and ran; encounter ~45 seconds.
Coleman was arrested (in Texas), extradited to Missouri, admitted being the person in surveillance photos and taking the money.
Charged as a persistent offender with second-degree robbery (forcibly steals under Mo. law), waived jury, convicted by the court, and sentenced to 10 years.
On appeal Coleman argued insufficient evidence of a use or threatened use of immediate physical force to constitute "forcibly steals."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence showed Coleman "forcibly stole" money (i.e., used or threatened immediate physical force)	State: Coleman’s concealed hand, oral demand for money in a bank, and ordering the manager not to move amounted to an (implicit or attempted) threat of immediate physical force supporting robbery conviction	Coleman: He made a nonthreatening request—no explicit threat, raised voice, or physical gesture amounting to immediate physical force; at most theft	Court affirmed: a reasonable person in a bank context would view the demand and conduct as an implicit threat of immediate physical force; evidence sufficient for second-degree robbery

State v. Brooks, 446 S.W.3d 673 (Mo. banc 2014) (demand and menacing conduct at a bank can constitute an implicit threat of immediate physical force)
State v. Stover, 388 S.W.3d 138 (Mo. banc 2012) (standard for sufficiency-of-evidence review)
State v. Oliver, 293 S.W.3d 437 (Mo. banc 2009) (same standard cited)
United States v. Gilmore, 282 F.3d 398 (6th Cir. 2002) (oral/written demands for money in a bank carry an implicit threat of harm if money not produced)
State v. Moore, 303 S.W.3d 515 (Mo. banc 2010) (interpretation of legislative intent and plain meaning of statutory text)
State v. Rowe, 63 S.W.3d 647 (Mo. banc 2002) (court must apply statutory text as written)