P. v. Toro CA4/3
A jury convicted defendants Jennifer Lynn Toro and Stevie Theodore Torres of what is commonly known as an “Estes robbery,” in which a defendant uses force or fear after the initial taking of the property. (People v. Estes (1983) 147 Cal.App.3d 23 (Estes).) Torres, joined by Toro, contends Estes was “wrongly decided” because it improperly expanded Penal Code section 211 “beyond its common law meaning.” Toro also argues insufficient evidence supports her conviction under the natural and probable consequences doctrine and thus the trial court erred in instructing the jury on that theory. We disagree with defendants’ contentions and affirm the judgments.
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