The opinion of the Court was delivered by
CLIFFORD, J.The narrow issue on this appeal, here by certification granted, 117 N.J. 159, 564 A.2d 877 (1989), is whether the sudden snatching of a purse from the grasp of its owner involves enough force to elevate the offense from theft from the person to robbery as defined by N.J.S.A. 2C:15-1a(1). Finding insufficient evidence that defendant had used force on his victim as contemplated by the statute, the Appellate Division reversed defendant’s conviction for robbery and remanded for the entry of an amended judgment of conviction for theft and for resentencing for that offense. 232 N.J.Super. 300, 305, 556 A.2d 1298 (1989). Because we conclude that defendant’s conduct did not involve the type of force envisioned when the Legislature amended the robbery statute, we affirm.
—A—
On August 27, 1986, Edythe Williams cashed her unemployment check at Proper Check Cashing, a concession located in the Woolworth store on Main Street in Paterson. Mrs. Williams placed the proceeds in a zipped compartment in the strapless, clutch-type purse that she carried under her arm. After purchasing a notebook in Woolworth’s, she left the store and headed for her car, which she had parked a couple of blocks away.
Mrs. Williams arrived at her car intending to drop off the notebook and continue shopping in the area. She went to the *211passenger side and put her key in the lock, all the while carrying the purse under her right arm. As Mrs. Williams stood in the street, defendant, Francisco Sein, walked up and stood close beside her on her left. Mrs. Williams turned to face the man, thinking he had approached to ask a question, but defendant said nothing. Instead, “he reached across [her] and just slid [her] pocketbook — which wasn’t very hard to do — from under [her] arm and took off,” running toward Main Street. There was no evidence that defendant used any force other than that required to slide the purse from beneath Mrs. Williams’ arm.
The police apprehended defendant, who was subsequently indicted for robbery. The robbery statute, N.J.S.A. 2C:15-1, reads as follows:
a. Robbery defined. A person is guilty of robbery if, in the course of committing a theft, he:
(1) Inflicts bodily injury or uses force upon another; or
(2) Threatens another with or purposely puts him in fear of immediate bodily injury; or
(3) Commits or threatens immediately to commit any crime of the first or second degree.
An act shall be deemed to be included in the phrase “in the course of committing a theft” if it occurs in an attempt to commit theft or in immediate flight after the attempt or commission.
b. Grading. Robbery is a crime of the second degree, except that it is a crime of the first degree if in the course of committing the theft the actor attempts to kill anyone, or purposely inflicts or attempts to inflict serious bodily injury, or is armed with, or uses or threatens the immediate use of a deadly weapon.
At trial, defendant moved at the conclusion of the State’s case for a judgment of acquittal in respect of the robbery charge, contending that the case should proceed only on the lesser-included offense of theft from the person, defined by N.J.S.A. 2C:20-3a as the “unlawful[] tak[ing], or exercising of] unlawful control over, movable property of another with purpose to deprive him thereof.” The crux of defendant’s argument was that there was no evidence in the record that the taking of Mrs. Williams’ purse was accompanied by the use of force against her person, a requirement for conviction under *212N.J.S.A. 2C:15-1a(1). The State, on the other hand, urged that a judgment of acquittal would be improper because the Legislature intended that the force used to remove the purse from the victim was sufficient to elevate the unlawful taking to a robbery. The trial court denied defendant’s motion, and the jury subsequently found defendant guilty of second-degree robbery.
On appeal, defendant contended that the trial court had erred by submitting the second-degree-robbery charge to the jury because there was no evidence that defendant had used force on Mrs. Williams in the course of the purse-snatching. The Appellate Division agreed, stating:
[T]he amended robbery statute, like the common law and N.J.S.A. 2A:141-1 (repealed), requires the application of force upon another greater than is necessary merely to remove the property from the victim’s person or control.
Where, as here, the victim is completely surprised by a purse-snatcher and offers no resistance, and force is applied only to the purse in order to separate it from the owner, the crime is not a robbery. Such force is not directed “upon another” but instead upon the object itself.
[ 232 N.J.Super. at 304-05, 556 A.2d 1298.]
The court reversed the robbery conviction and remanded for the entry of a judgment of conviction for theft and for resentencing for that offense. Id. at 305, 556 A.2d 1298.
Before us, the State argues that the Appellate Division’s construction of the “uses force upon another” language in the robbery statute, N.J.S.A. 2C:15-la(l), both misconstrues the plain meaning of the statute and contravenes the relevant legislative intent. According to the State, the Appellate Division’s standard will “change the focus of a robbery committed through the use of force from the conduct of the perpetrator to the nature of the property that he stole * * * and the particular characteristics of the victim as well as the victim’s actions.” In addition, the State submits that the standard established by the Appellate Division to determine the amount of force necessary to effect a robbery is “inexact and unworkable,” and that therefore jurors will be required to use concepts founded in the *213science of physics to determine whether more force was used than that quantum necessary merely to remove the object.
—B—
Cases involving “snatching” have required courts to determine where to draw the line between robbery and the lesser offense of larceny from the person. A certain amount of “force” is necessary to take property from the person of another, but whether the amount necessary merely to accomplish that taking is sufficient to warrant the more serious penalties associated with robbery has vexed those courts that have considered the question.
Some jurisdictions have construed the term “force” as used in the state’s robbery statute to mean mere physical force or energy (see, e.g., Raymond v. State, 467 A.2d 161 (Me.1983)), while others have rejected hypertechnical distinctions in favor of a view that acknowledges that snatching an object from the grasp of the owner increases the risk of danger to the victim and justifies enhanced punishment. E.g., People v. Santiago, 62 A.D.2d 572, 405 N.Y.S.2d 752 (1978), aff'd, 48 N.Y.2d 1023, 402 N.E.2d 121, 425 N.Y.S.2d 782 (1980); Commonwealth v. Brown, 506 Pa. 169, 484 A.2d 738 (1984). Those jurisdictions implicitly recognize that victims do not turn over their property willingly, even if they do not resist or struggle with a thief. Thus, the amount of physical energy necessary to take the property is deemed sufficient to support a robbery conviction.
The predominant view, however, is that there is insufficient force to constitute robbery when the thief snatches property from the owner’s grasp so suddenly that the owner cannot offer any resistance to the taking. See W. LaFave & A. Scott, Criminal Law § 8.11(d), at 781 (2d ed.1986). This “majority rule” has been set forth in the following terms:
[A] simple snatching or sudden taking of property from the person of another does not of itself involve sufficient force to constitute robbery, though the act may be robbery where a struggle ensues, the victim is injured in the taking, or *214the property is so attached to the victim’s person or clothing as to create resistance to the taking.
[People v. Patton, 76 Ill.24 45, 49, 27 Ill.Dec. 766, 767, 389 N.E.2d 1174, 1175 (1979).]
The Illinois Supreme Court confirmed that rule in People v. Taylor, 129 Ill.2d 80, 133 Ill.Dec. 466, 541 N.E.2d 677 (1989):
The force required to overcome the physical resistance created by the attachment of an item to the person or clothing of the owner is to be distinguished from “the mere physical effort” which must occur whenever any item, not attached to the person or clothing of the owner, is transferred from one person (the owner) to another person (the taker). It will be a theft, therefore, and not a robbery, when the evidence “show[s] no more force than the mere physical effort of taking the pocketbook from [the victim’s] person and transferring it to [the defendant].”
[Id. at 84, 133 Ill.Dec. at 468, 541 N.E.2d at 679 (citation omitted).]
That majority rule has been adopted in several other jurisdictions. See, e.g., Richburg v. State, 439 So.2d 788 (Ala.Crim. App.1983); Walker v. State, 546 So.2d 1165 (Fla.Dist.Ct.App. 1989); Commonwealth v. Davis, 7 Mass.App. 9, 385 N.E.2d 278 (1979). See generally Annotation, “Purse Snatching as Robbery or Theft,” 42 A.L.R.3d 1381, 1382-88 (1972 & Supp.1990) (collecting cases).
The legislative history of New Jersey’s robbery statute, N.J.S.A. 2C:15-1, when read in the context of the Code Commentary on theft, reveals that our Legislature intended to adopt the majority rule.
—C—
At common law, robbery was defined in New Jersey as “the felonious taking of personal property from the person or custody of another by force or intimidation.” State v. Butler, 27 N.J. 560, 589, 143 A.2d 530 (1958). The pre-Code robbery statute, N.J.S.A. 2A.141-1, codified the common law. State v. Carlos, 187 N.J.Super. 406, 413, 455 A.2d 89 (App.Div.1982), certif. denied, 93 N.J. 297, 460 A. 2d 693 (1983); State v. Cottone, 52 N.J.Super. 316, 323, 145 A.2d 509 (App.Div.1958), certif. denied, 28 N.J. 527, 147 A.2d 305 (1959).
The Appellate Division summarized the general state of the law of robbery under the pre-Code statute in State v. Culver, *215109 N.J.Super. 108, 262 A.2d 422, certif. denied, 56 N.J. 473, 267 A.2d 55 (1970), where it stated:
N.J.S.A. 2A:141-1, provides that any person who forcibly takes from the person of another money or personal goods and chattels of any value whatever by violence or putting him in fear, is guilty of a high misdemeanor. Thus, force or intimidation is a necessary element of the crime and must precede or be concomitant with the taking. The property stolen need not have been in contact with the person from whom it was taken at the time it was stolen, and if taken by fear it must be the result of such demonstration or threat as to create reasonable apprehension on the part of the victim that, if the theft were resisted, force would be used. While a secret or sudden taking of property from the owner without putting him in fear and without open violence is deemed larceny, if there be a struggle to keep it or any violence or disruption, the taking is robbery.
[Id. at 111-12, 262 A.2d 422 (citations omitted) (emphasis added).]
The foregoing summary suggests that at the time N.J.S.A. 2A:141-1 was in effect, New Jersey followed the majority view as stated in People v. Patton, supra, 76 Ill.2d at 49, 389 N.E.2d at 1175, set forth above at 213-14.
In 1979, the Legislature revamped the criminal laws by enacting the New Jersey Code of Criminal Justice, N.J.S.A. 2C.1-1 to 98-4. Under N.J.S.A. 2C:15-1a, as originally enacted, “[a] person [was] guilty of robbery if, in the course of committing a theft, he: (1) [i]nflicts bodily injury upon another; or (2) [threatens another with or purposely puts him in fear of immediate bodily injury; or (3) [c]ommits or threatens immediately to commit any crime of the first or second degree.”
In 1981, however, the Legislature amended N.J.S.A. 2C:15-1a(1) to read that a person is guilty of robbery if in the course of committing a theft he “[ijnflicts bodily injury or uses force upon another.” L. 1981, c. 22, § 1 (emphasis added). The Legislature’s intention regarding the addition of the “or uses force” language is made clear by the following Statement of the Senate Judiciary Committee:
Senate Bill No. 885 amends N.J.S.A. 20:15-1 to clarify that a person is guilty of robbery if he uses any force upon another in the course of committing a theft. Under present law only a person who inflicts bodily injury upon another in the course of committing a theft is guilty of robbery. Senate Bill 885 extends the definition of robbery to cover the so-called “blind-side” mugging. This occurs when a person commits an act of theft — for example a purse snatching — by *216approaching the victim from behind and using some degree of force to wrest the object of his theft from, the victim. Often, however, no bodily injury is inflicted in these cases and therefore the offenses committed could be found to be theft rather than robbery.
[Statement of the Senate Judiciary Committee to Senate Bill 885 (Apr. 21, 1980) (emphasis added).]
The State contends that that Statement shows that the Legislature contemplated that a sudden, surprise snatching of property held in the grasp of another or in some way in contact with the person of another involves the use of force sufficient to elevate the taking to a robbery.
To the contrary, that the Legislature intended to broaden the concept of force beyond the pre-Code understanding of that term is not at all clear. The Senate Judiciary Committee Statement begins by saying the amendment is to “clarify that a person is guilty of robbery if he uses force upon another in the course of committing a theft.” (Emphasis added.) That suggests that the omission of the “or uses force” language in the Code as originally enacted in 1979 was an oversight. In amending N.J.S.A. 2C:15-1a(1), the Legislature merely intended to clarify that the type of force required to support a robbery conviction under the pre-Code statute still would be sufficient to elevate a theft to a robbery.
As we indicated earlier, see supra at 213, 214, “a simple snatching or sudden taking of property from the person of another does not of itself involve sufficient force to constitute robbery” under the pre-Code statute, and nothing in the Senate Judiciary Committee Statement undercuts that standard. Although the Committee Statement refers to a “purse snatching” as an example of the conduct the amendment was intended to cover, it goes on to state that snatchings rising to the level of robbery include only those that involve “some degree of force to wrest the object” from the victim. (Emphasis added.) To “wrest” is to “pull, force, or move by violent wringing or twisting movements.” Webster’s Third New International Dictionary 2640 (1971). The Legislature apparently determined that the violence associated with “wresting” is deserving *217of more severe punishment. It did not, however, intend to eliminate the requirement that robbery by use of force include force exerted “upon another.”
Moreover, the Commentary to the Code definition of “theft” strongly suggests that the Legislature did not intend that a surprise purse-snatching unaccompanied by injury, threat, struggle, or attempted resistance would constitute the crime of robbery. In discussing N.J.S.A. 2C:20-3, which provides in pertinent part that “a person is guilty of theft if he unlawfully takes, or exercises unlawful control over, movable property of another with purpose to deprive him thereof,” the Legislature made clear the following:
The crime here defined may be committed in many ways, i.e., by a stranger acting by stealth or snatching from the presence or even the grasp of the owner or by a person entrusted with the property as agent, bailee, trustee, fiduciary or otherwise.
[II New Jersey Penal Code: Final Report of the New Jersey Criminal Law Revision Commission § 2C:20-3 commentary 2 at 222 (Oct. 1971) (emphasis added).]
The theft statute thus includes purse-snatchings from the grasp of an owner, while the robbery statute includes purse-snatchings that involve some degree of force to wrest the object from the victim. The only way to reconcile the two statutes is to hold that robbery requires more force than that necessary merely to snatch the object.
If the Legislature had intended that the amount of force necessary to snatch the object would be sufficient to constitute a robbery, it could have amended the theft statute to indicate that it includes only those snatchings in which the object of the theft is loose or can be cut loose, but not those in which the object must be removed from the' victim. It did not do so.
The standard we adopt today continues the focus of a robbery on the conduct of the perpetrator rather than on the nature of the property stolen or the characteristics of the victim and his or her actions. Furthermore, we do not agree with the State’s contention that this standard is “inexact and unworkable.” If in fact jurors will henceforth be required to resort to concepts founded in the science of physics to determine whether *218more force was used than that quantum necessary merely to remove the object, that is hardly a dismaying by-product of a correct interpretation of the statute. Such concepts are used frequently by juries in their deliberations and are entirely within their ken.
—D—
The inclusion of the “uses force upon another” language in the robbery statute was a clarification that a taking accompanied by the use of force, as understood at common law and prior to the enactment of the Code, still would constitute a robbery. There is no indication that the Legislature intended to change the pre-Code rule that “a secret or sudden taking of property from the owner without putting him in fear and without open violence is deemed larceny, [but] if there be struggle to keep it or any violence or disruption, the taking is robbery.” State v. Culver, supra, 109 N.J.Super. at 111-12, 262 A.2d 422. To the extent that the robbery statute and the Senate Judiciary Committee Statement are burdened with ambiguity, as so persuasively argued by the Chief Justice in his dissent, that ambiguity surely cannot inure to the benefit of the State. “[P]enal statutes that are open to more than one reasonable construction must be construed strictly against the State.” State v. Churchdale Leasing, 115 N.J. 83, 102, 557 A.2d 277 (1989).
Because there is no evidence that defendant’s conduct involved the type of force sufficient to elevate the theft to a robbery under N.J.S.A. 2C:15-1a(1), the judgment of the Appellate Division is affirmed.