id. at 1313. Before doing so, however, the Welch court noted that the defendant there pleaded guilty prior to the Florida Supreme Court’s Robinson decision in a circuit court within Florida’s Fourth District Court of Appeal, which “had not yet spoken definitively on the question” of whether mere snatching was sufficient. Id. at 1311 & n. 32. Unlike the defendant in Welch, Defendant was convicted within a Florida appel late district that had “spoken definitively on the question.” Defendant’s 1986 conviction was in Hillsborough County, which is within the Second District Court of Appeal. The Second District ruled both prior to and after 1986 that more than mere “snatching” is required to sustain a robbery conviction. See, e.g., Adams v. State, 295 So.2d 114, 116 (Fla. 2d DCA 1974) (<HOLDING>); Goldsmith v. State, 573 So.2d 445, 445 (Fla.
holding that the district court correctly instructed the jury that there had to be a substantial similarity between the indictment and the proof in order to find the defendant guilty holding that the trial court correctly instructed the jury that the use of physical force to overcome victims resistance was necessary for offense to amount to robbery holding that the district court correctly declined to instruct the jury that the government was required to prove as an element of the offense that the defendant did not intend to establish a life with his wife holding that the trial court correctly instructed the jury that the defendant had to establish by evidence that outweighed the evidence against him that he lacked the capacity to form specific intent holding that the trial judge correctly instructed the jury that in resolving whether the crime occurred in tennessee they must be persuaded beyond a reasonable doubt from the evidence introduced on that issue