State v. Truong, 168 Wash. App. 529

Sindy Truong is charged with two counts of first degree robbery arising from an incident on a Seattle bus involving Redmon-Beckstead and Decoste.
Truong allegedly took Redmon-Beckstead’s Zune and headphones and, with others, used force to retain the property amid a confrontation on the bus.
Video and witness testimony show Truong joined in assaults after the initial taking and through the remainder of the incident.
The trial court waived exclusive adult jurisdiction; Truong was tried in juvenile court and found guilty of first degree robbery for Redmon-Beckstead and second degree robbery for Decoste’s cigarettes, with accomplice liability applied to both.
Truong appeals arguing insufficient evidence to support both robbery convictions and challenges to the accomplice theories.
The appellate court examines the sufficiency of evidence under a transactional analysis of robbery, including retention-after-taking and accomplice liability under RCW 9A.08.020.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is there sufficient evidence for first degree robbery?	State argues transactional retention satisfied force element.	Truong argues Johnson controls; no force to retain.	Yes; sufficient evidence of force to retain property.
Was Truong properly found liable as an accomplice for Redmon-Beckstead’s robbery?	State contends accomplice liability proven by aiding retention.	Truong argues lack of aiding conduct or knowledge.	Accomplice liability established.
Is there sufficient evidence for second degree robbery of Decoste’s cigarettes?	State asserts Truong knowingly aided the robbery in concert with others.	Truong challenges sufficiency of aiding conduct.	Sufficient evidence supports second degree robbery.
Does possession play a required role under the transactional analysis for robbery?	State relies on continuing threat/retention to satisfy force element.	Truong relies on Johnson to limit retention force.	Retention of property can support robbery without initial possession by the taker.

State v. Handburgh, 119 Wn.2d 284 (1992) (robbery can be satisfied by force to retain property, not only at taking)
State v. Manchester, 57 Wn. App. 765 (1990) (transactional view of robbery; force during escape may satisfy the force element)
State v. Johnson, 155 Wn.2d 609 (2005) (limits transactional expansion; force must relate to taking or retention, not escape)
State v. Parra, 96 Wn. App. 95 (1999) (recognizes sufficiency of force to gain or retain possession)
State v. Hayden, 28 Wn. App. 935 (1981) (possession not essential element of first degree robbery)