TALBOT, J.

We granted defendant's delayed application for leave to appeal1 the trial court's denial of his request to withdraw his guilty plea to a charge of armed robbery. MCL 750.529. The trial court sentenced defendant, as a fourth-offense habitual offender, MCL 769.12, to 24 to 40 years' imprisonment. We affirm.

I. FACTUAL AND PROCEDURAL HISTORY

Defendant was initially charged with two separate armed robberies, which occurred on consecutive days at different locations involving a Clark gas station and an Admiral tobacco shop. As part of a "package" deal, defendant pleaded nolo contendere with regard to the Clark gas station charge and guilty with regard to the Admiral tobacco shop charge. Difficulties were encountered when the trial court tried to establish a factual basis for defendant's pleas. In this appeal, we are interested solely in defendant's plea in the Admiral tobacco shop case.

With regard to the Admiral tobacco shop, defendant acknowledged that his intent, upon entering the store, was to steal money. Defendant also admitted that he had placed his hand "up under" his coat, suggesting the possession of a weapon, and told the clerk, "[Y]ou know what this is, just give me what I want." The trial court accepted the plea finding it "to be knowing, voluntary, understanding, and accurate." Subsequently, defendant was sentenced to 24 to 40 years' imprisonment for that armed robbery.

Approximately one year after the pleas were accepted and six months after being sentenced, defendant filed a motion seeking to withdraw his pleas. Defendant argued that his plea in the Admiral tobacco shop case was deficient because there was no demonstration or showing that defendant actually took any property from the store. Following the submission of additional briefs, the trial court issued a written opinion and order denying defendant's motion to withdraw his pleas. This appeal ensued.

II. STANDARD OF REVIEW

The issue before this Court can be summarized as whether a completed larceny is necessary to sustain a conviction for armed robbery, pursuant to MCL 750.529. Consequently, the outcome of this appeal is completely dependent on the statutory language comprising MCL 750.529 and MCL 750.530. It is well recognized:

This Court also reviews de novo as a question of law whether specific conduct falls within the prohibitions of a statute. People v. Adkins, 272 Mich.App. 37, 39, 724 N.W.2d 710 (2006). Relevant to this appeal, we would further note that there exists no absolute right to withdraw a guilty plea, which decision is within the trial court's discretion. People v. Ovalle, 222 Mich.App. 463, 465, 564 N.W.2d 147 (1997).

III. ANALYSIS

The four statutes pertaining to robbery are contained within Chapter LXXVIII of the Michigan Penal Code.2 In this appeal, we are concerned with the statutes pertaining to robbery and unarmed robbery following their legislative revision in 2004 PA 128. Specifically, MCL 750.529, defining armed robbery, currently provides:

Robbery is defined within MCL 750.530, which states:

It must be determined, on the basis of these recent revisions, whether a perpetrator must actually commit a completed larceny to be convicted of an armed robbery.3 Specifically, with reference to the issue on appeal, we must address whether the trial court erred by accepting defendant's guilty plea to the offense of armed robbery when there was no proof or evidence of a completed larceny. We find that the statutory language now encompasses attempts and that, as a result, a completed larceny is no longer required for a conviction of armed robbery.4

It is undisputed that MCL 750.529 and MCL 750.530 must be read together because armed robbery requires that a person be "engage[d] in conduct proscribed under [MCL 750.530]." MCL 750.529. In addition, for a robbery to rise to the level of an armed robbery, MCL 750.529 requires that the individual "possess[] a dangerous weapon or an article used or fashioned in a manner to lead any person ... to reasonably believe the article is a dangerous weapon, or who represents orally or otherwise that he or she is in possession of a dangerous weapon. ..." Notably, defendant acknowledged during his plea hearing that he acted in a manner to suggest to the store clerk that he possessed a weapon. Hence, the issue before us is restricted solely to whether a larceny must be completed for defendant's armed robbery conviction to stand.

Clearly, other than separately requiring the existence or representation of the presence of a weapon, the crime of armed robbery is restricted to the "conduct proscribed under section 530. ..." MCL 750.529. In turn, MCL 750.530 indicates that the conduct "proscribed" is the use of "force or violence" while "in the course of committing a larceny of any money or other property that may be the subject of larceny. ..." Our analysis must focus on the definition, contained in MCL 750.530(2), of the phrase "in the course of committing a larceny," which "includes acts that occur in an attempt to commit the larceny, or during the commission of the larceny, or in flight or attempted flight after the commission of the larceny, or in an attempt to retain possession of the property."5 (Emphasis added.) This Court has no alternative but to strictly adhere to the language used by the Legislature in revising this statute and not seek to attribute either motive or reasoning beyond the plain and ordinary meaning of the wording chosen for use. As such, the crime of armed robbery now also encompasses attempts to commit that offense.

"Where, as here, a statute supplies its own glossary, courts may not import any other interpretation, but must apply the meaning of the terms as expressly defined." Detroit v. Muzzin & Vincenti, Inc., 74 Mich.App. 634, 639, 254 N.W.2d 599 (1977). When dealing with statutory language, it is a well-defined precept that,

In other words,

The legislative definition of "in the course of committing a larceny" specifically "includes acts that occur in an attempt to commit the larceny. ..." The term "attempt," which is not defined within the statute, is recognized to mean:

As such, the statutory language specifically considers and incorporates acts taken in an attempt to commit a larceny, regardless of whether the act is completed. This is consistent with the language of MCL 750.530(2), which distinguishes, by the use of the word "or," acts committed in "an attempt to commit the larceny" from those acts occurring "during the commission of the larceny" or any subsequent acts comprising flight or efforts to retain any property. The term "or" is "used to connect words, phrases, or clauses representing alternatives." Random House Webster's College Dictionary (1997). Hence, an attempt to commit a larceny comprises a separate and distinct action and is not merely a component of a completed larceny. In addition, we would note that MCL 750.530(2) defines "in the course of committing a larceny" (emphasis added) and not "the larceny." The term "a larceny" denotes a more generic, non-specific or generalized act. The fact that the term "the larceny" is subsequently used within this subsection of the statute merely denotes a reference back to the more generalized "a larceny." Logically, acts taken in the process of committing a larceny necessarily include steps or behaviors occurring at any point in the continuum, despite whether they are successfully completed. This language necessarily demonstrates the Legislature's intent to include attempts to commit a larceny, both by implication and by the specific language contained in this statutory provision.

Consistent with the statutory language, which expands the crime of armed robbery to include attempts, is the recently revised criminal jury instruction relating to this crime.6 The language of the criminal jury instruction pertaining to armed robbery is clearly consistent with the language of MCL 750.529 and MCL 750.530, providing:

An "attempt" is defined within this section of the criminal jury instructions as having "two elements":

Clearly, the criminal jury instructions have specifically been revised to fully coincide with the statutory language of MCL 750.529 and MCL 750.5307 and to include a definition of the term "attempt" separate from the more general instruction of a crime comprising an attempt. CJI2d 9.1.

We would note that the immediate prior version of the relevant statute, MCL 750.529, before its amendment by 2004 PA 128, read:

In revising this language, the Legislature not only recognized the actual possession of a weapon or representation by a criminal that he or she is armed, irrespective of the actual presence of a weapon, but also removed the language mandating the actual behavior of to "rob, steal and take. ..." Had the Legislature not intended a broader revision of the statute, this language could have remained untouched. In addition, the revised language helps to delineate this offense from assault with the intent to rob and steal while armed, MCL 750.89, which statute provides:

Hence, MCL 750.89, while similar to MCL 750.529, requires the additional element of an actual "assault."8

Clearly, 2004 PA 128 was enacted, at least in part, to legislatively reinstitute a transactional approach to this crime, in response to our Supreme Court's decision in People v. Randolph, 466 Mich. 532, 648 N.W.2d 164 (2002). While the Legislature was motivated to enact a provision that would establish a transactional approach to robbery in order to not limit or restrict to a temporal point during the commission of the crime when the threat of violence or use of a weapon had to occur, the statutory language has exceeded this restricted purpose and it is beyond the role of this Court to speculate regarding what the Legislature intended to do. Rather, we can only enforce the language of the statute as it is actually written.

We would assert that the two remaining criminal statutes in this chapter of the Penal Code also reflect this broader perspective. Notably, the carjacking statute, MCL 750.529a, is almost identical to the wording of MCL 750.530. Specifically, MCL 750.529a provides, in relevant part:

As already noted, 2004 PA 128 also revised this statute. Similar to MCL 750.529, the earlier version of the carjacking statute provided, in relevant part:

Once again, the Legislature removed the language "robs, steals, or takes," insinuating that the revised statute was intended to include attempts to commit the designated crime. In contrast, MCL 750.531, which has not been subject to any recent revisions, clearly indicates that it encompasses the "intent" to commit the crime of bank robbery. Specifically, MCL 750.531 states:

This is important to demonstrate that the concept or legislative act of including language that encompasses an attempt within the statutory definition of a crime is neither unusual nor inconsistent with the most current revisions pursuant to 2004 PA 128. In fact, the revisions to MCL 750.529 through MCL 750.530 now render all of the statutes within this chapter of the Penal Code internally consistent.9

A recognized "rule of statutory interpretation provides that well-settled common-law principles are not to be abolished by implication, and when an ambiguous statute contravenes the common law, it must be interpreted so that it makes the least change in the common law." Heinz v. Chicago Rd. Investment Co., 216 Mich.App. 289, 295, 549 N.W.2d 47 (1996). However, simultaneously, "this Court is instructed to avoid any construction that would render a statute, or any part of it, surplusage or nugatory." Id. at 295-296, 549 N.W.2d 47. First and foremost, concerns regarding the revised statute's alleged abrogation of the common law by no longer requiring a completed larceny are unnecessary. This particular concern pertaining to statutory interpretation pertains to ambiguous statutes and we believe the language of MCL 750.529 and MCL 750.530 to be clear in encompassing attempts within the purview of "in the course of committing a larceny" by definition. Second, the very fact that the Legislature has elected to use a transactional approach is according to our Supreme Court, in and of itself "contrary to the common law." Randolph, 466 Mich. at 545, 648 N.W.2d 164. If the Legislature intended this statute to adopt a transactional approach, it is reasonable to assume it was aware of its abrogation of the common law and intended to take it a step further. See 22 Michigan Civil Jurisprudence, Statutes (2009), § 220. In addition, the statute, even before its revision, superseded the common law. Specifically:

Finally, as a general observation, in defining a robbery, the "essential elements of unarmed robbery are assault with force and violence while the defendant is not armed, accompanied by the intent to rob and steal." 4 Gillespie, Michigan Criminal Law & Procedure (2d), § 133:2, p. 400. Hence, it is the violence or threat of force and the intent that constitute the primary elements rather than the successful completion of a particular act that comprise this offense.

Further, the legislative history pertaining to the statutory revisions supports a holding that the inclusion of attempts within the offense was deliberate. Specifically, in discussing the content of the proposed revisions, it was noted:

Unfortunately, following revision of the statutory language, the application and interpretation of these provisions has not been consistent within caselaw. In People v. Chambers, 277 Mich.App. 1, 8 n. 7, 742 N.W.2d 610 (2007), this Court acknowledged the revision of MCL 750.529 and MCL 750.530 and noted the alteration of previously recognized elements defining these crimes. Subsequently, in an unpublished opinion, this Court, citing Chambers opined, in pertinent part:

Other opinions appear to retain the previous requirements of a completed larceny but lack a certain level of clarity in their analysis. By way of example, in People v. Thomas, unpublished opinion per curiam of the Court of Appeals, issued October 6, 2009 (Docket No. 287382), 2009 WL 3199543, the Court distinguished between the revised armed robbery statute and the bank robbery statute. However, in undertaking this analysis the Court did not recognize any significant departure in the elements for armed robbery from caselaw that existed before the revision of MCL 750.529, resulting in the determination by the Court that "[a]rmed robbery continues to require a theft from a person. ..." Id., unpub. op. p. 2. Notably, in and of itself this is an inaccuracy because the current statute encompasses the use or threat of force (with the presence or representation of a weapon) against a person while "in the course of committing a larceny of any money or other property that may be the subject of larceny. ..." MCL 750.529; MCL 750.530(1). It does not require a direct "taking" or "theft from a person." Similarly, a statement by this Court in People v. Monk, unpublished opinion per curiam of the Court of Appeals, issued January 22, 2009 (Docket No. 280291), 2009 WL 153431, contains an obvious contradiction. On the one hand, the Court states, "Acts included in the phrase `in the course of committing a larceny' include all acts that occur during a larceny's attempt or commission. ... An attempted or committed larceny by an armed individual, or by a person the victim reasonably believes is armed, is required under the statute." Id., unpub. op. p. 2. However, this statement is immediately followed by a reference indicating the necessity of a taking despite recognition that the statute encompasses attempts to commit the crime. Specifically, the Court opined, "The statute does not expressly require that any property actually taken must be owned by the victim. Rather, property must just be taken from the victim or his presence in the course of a larceny."10 Id.

Courts must proceed with greater caution in their use and reliance on prior published opinions delineating the elements of armed robbery, which preceded the revision of MCL 750.529. "[A] change by amendment in the phraseology of a statute is presumed to indicate a legislative purpose to change the meaning." 3A Michigan Pleading & Practice (2d ed., 2007 revised vol.), § 36:146, p. 251; see, also, People v. Auto. Serv. Councils of Mich., Inc., 123 Mich.App. 774, 787, 333 N.W.2d 352 (1983) ("It is reasonable to presume some intentionality in the insertion of this additional language."). Clearly, the Legislature has enacted changes affecting the elements comprising this offense and it is our responsibility to correctly apply the revised language of MCL 750.529 to the particular evidence and facts of each individual case.

IV. CONCLUSION

"[W]hen determining whether sufficient evidence has been presented to sustain a conviction, a court must view the evidence in a light most favorable to the prosecution and determine whether any rational trier of fact could have found that the essential elements of the crime were proven beyond a reasonable doubt." People v. Wolfe, 440 Mich. 508, 515, 489 N.W.2d 748 (1992), amended 441 Mich. 1201 (1992). In the factual circumstances of this case, defendant acknowledged that he represented to the store clerk that he was in possession of a weapon at the Admiral tobacco shop. From the colloquy at sentencing, it was also established that defendant had the intent to take or obtain money from the store's cash register. It was not established that defendant had any intention to harm the store's clerk. While defendant was not successful in that he left the store without money from the cash register, sufficient elements of the crime were established to sustain his conviction for armed robbery based on the language of the statute.

Affirmed.

OWENS, P.J., concurred.

GLEICHER, J. (dissenting).

I respectfully dissent. In my view, the Legislature did not intend that its 2004 amendment of the armed robbery statute would fundamentally alter the elements of that offense by eliminating the requirement of a completed larceny.

I. UNDERLYING FACTS AND PROCEEDINGS

On July 13, 2006, a man matching defendant's description entered a Clark gas station in Norton Shores, declared that he had a gun, and ordered the attendant to give him all the money in the cash register. After the attendant complied, the assailant pushed her into a back room and fled. The next day, defendant entered the Admiral tobacco shop (Admiral Tobacco) in Roosevelt Park, approached the clerk with his hand in his jacket, and announced, "[Y]ou know what this is, just give me what I want." The clerk did not give defendant any money or property, and defendant fled from the store without having stolen anything. Defendant apparently broke his leg in flight from the store, and the police eventually apprehended him. When the police arrested defendant, they noted that he wore on his body and possessed in his vehicle the same clothing worn by the man who had robbed the Clark station the previous day.

The prosecutor charged defendant with armed robbery of the Clark station (Case No. 06-053668-FC). In a separate complaint arising from the Admiral Tobacco events, the prosecutor charged defendant with assault with intent to rob while armed, MCL 750.89, and armed robbery, MCL 750.529 (Case No. 06-053640-FC). At a January 2007 hearing, the prosecutor informed the circuit court "that [defendant] will be offering ... pleas of guilty in both files." The prosecutor advised that in the Admiral Tobacco case, the prosecution had elected to dismiss the assault with intent to rob while armed charge and accept defendant's guilty plea to a charge of armed robbery. Defense counsel summarized the parties' agreement that defendant's sentence would "not ... exceed 24 years on the minimum-maximum at the Michigan Department of Corrections."

After apprising defendant of his constitutional and other rights, the circuit court moved on to establish a factual predicate for defendant's plea to the Clark station robbery. However, defendant denied having represented to the station attendant that he possessed a weapon. When the circuit court offered to allow the parties additional time to further discuss defendant's guilty plea, the prosecutor suggested that the court instead establish the "factual scenario of the Admiral" Tobacco incident. Under questioning by the prosecutor, defendant admitted that he had entered Admiral Tobacco with the intent to steal money, had his hand "up under" his coat, and told the clerk, "[Y]ou know what this is, just give me what I want." The prosecutor's questioning continued as follows:

The parties then returned to presenting a factual basis for defendant's plea to the Clark station robbery. Defense counsel averred that defendant was high on cocaine during the Clark station robbery and could not recall the details of the crime. Defense counsel proposed that defendant could enter a no contest plea. The circuit court agreed it would resort to a police report to establish the factual predicate for defendant's no contest plea, summarizing,

On February 9, 2007, the court sentenced defendant to concurrent terms of 24 to 40 years' imprisonment for the Clark station and Admiral Tobacco robberies.

In October 2007, defendant moved to withdraw both his pleas, contending that the circuit court neglected to secure an adequate factual foundation for either plea. According to defendant, the Admiral Tobacco plea discussions revealed no evidence that he had committed a larceny, and the police report used to supply the factual basis of the Clark station plea did not sufficiently identify defendant as the robber. The circuit court denied defendant's motions, ruling (1) with respect to the Admiral Tobacco plea, that the language of the armed robbery statute allows conviction based on an attempted larceny, which the plea discussions substantiated, and (2) concerning the Clark station robbery, that the entirety of the police report and plea proceeding amply established defendant's participation in the Clark station robbery. This Court granted defendant's delayed application for leave to appeal, "limited to case no. 06-053640-FC [Admiral Tobacco] on the issue of a completed larceny only. In all other respects, the delayed application for leave is denied." People v. Williams, unpublished order of the Court of Appeals, entered June 16, 2008 (Docket No. 284585).

II. ANALYSIS

"There is no absolute right to withdraw a guilty plea once it has been accepted by the trial court." People v. Montrose (After Remand), 201 Mich.App. 378, 380, 506 N.W.2d 565 (1993). Where, as here, a defendant moves to withdraw his or her plea after sentencing occurs, "[t]he trial court's decision will not be disturbed on appeal absent a clear abuse of discretion that resulted in a miscarriage of justice." People v. Boatman, 273 Mich.App. 405, 406-407, 730 N.W.2d 251 (2006). "In reviewing the adequacy of the factual basis for a plea, this Court examines whether the factfinder could properly convict on the facts elicited from the defendant at the plea proceeding." People v. Brownfield (After Remand), 216 Mich.App. 429, 431, 548 N.W.2d 248 (1996), citing People v. Booth, 414 Mich. 343, 360, 324 N.W.2d 741 (1982).

Defendant insists that because he "never stole, moved or touched property" during the Admiral Tobacco incident, a fact-finder could not have convicted him of an armed robbery. Defendant emphasizes that larceny constitutes "an integral and necessary element of armed robbery," and absent evidence of a completed larceny, the circuit court erred by accepting his guilty plea to violating MCL 750.529. The majority rejects defendant's argument, holding that the Legislature's 2004 amendment of the robbery statute "specifically considers and incorporates acts taken in an attempt to commit a larceny, regardless of whether the act is completed." Ante at 388. In my estimation, the majority erroneously reaches its holding by reading into the statute language that the Legislature did not incorporate into the statute.

I approach my analysis bearing in mind that "[u]nderlying the criminal statutes of this state is the common law." People v. McDonald, 409 Mich. 110, 117, 293 N.W.2d 588 (1980). The common-law definition of a crime binds Michigan courts until the Legislature modifies the elements of the crime. People v. Perkins, 468 Mich. 448, 455, 662 N.W.2d 727 (2003). In People v. Covelesky, 217 Mich. 90, 100, 185 N.W. 770 (1921), our Supreme Court instructed:

When a statute incorporates general common-law terms to describe an offense, we thus construe the statutory crime through the lens of common-law definitions. People v. Riddle, 467 Mich. 116, 125, 649 N.W.2d 30 (2002). In Riddle, our Supreme Court quoted approvingly the following relevant passage from Morissette v. United States, 342 U.S. 246, 263, 72 S.Ct. 240, 96 L.Ed. 288 (1952):

Michigan's original robbery statutes derived from the common-law crime of robbery, and fashioned that crime into two grades. People v. Calvin, 60 Mich. 113, 120, 26 N.W. 851 (1886). In Calvin, our Supreme Court distinguished the two grades of robbery as "one in which the robbery is committed by an assault and robbery from the person, the robber being armed with a dangerous weapon, ... the other in which the offense is perpetrated by force and violence, or by assault or putting in fear, and robbing, stealing, and taking from the person of another, the robber not being armed with a dangerous weapon. ..." Id. at 119, 26 N.W. 851. Today, MCL 750.530 delineates the elements of an unarmed robbery, and MCL 750.529 defines armed robbery by adding to MCL 750.530 the element that the robber possessed a dangerous weapon or "an article used or fashioned in a manner to lead any person present to reasonably believe the article [was] a dangerous weapon, or [the robber] represent[ed] orally or otherwise that he or she [was] in possession of a dangerous weapon. ..."

Under the common law, the crime of robbery indisputably included as an essential element the commission of a larceny. "Since, by definition, robbery includes larceny, robbery requires a caption and asportation of the property of another." Wharton's Criminal Law (15th ed.), § 457, p. 13. Wharton further instructs that a defendant accomplishes "a caption when... [he] takes possession; he takes possession when he exercises dominion and control over the property." Id. Professors Wayne LaFave and Austin Scott also explain, in relevant part:

Larceny, in turn, "requires that there be a `trespass in the taking,' i.e., that the thief take the property out of the possession of its possessor. ..." Id., § 85, p. 622.

In Covelesky, 217 Mich. at 96-97, 185 N.W. 770, our Supreme Court observed that Michigan's robbery statutes embody the common-law offense of robbery:

In Saks v. St. Paul Mercury Indemnity Co., 308 Mich. 719, 723-724, 14 N.W.2d 547 (1944), the Supreme Court quoted approvingly the following from a decision of the Washington Supreme Court, Cartier Drug Co. v. Maryland Cas. Co., 181 Wn. 146, 149, 42 P.2d 37 (1935): "`In the administration of criminal law, two distinct elements are held to be necessary to the crime of robbery: (1) Putting the victim in fear of violence to his person or property; and (2) the taking of money, property, or thing of value from his person or in his presence.'" And in People v. LaTeur, 39 Mich.App. 700, 706, 198 N.W.2d 727 (1972), this Court noted that "[l]arceny is one of the essential elements of an armed robbery charge." More recently, in People v. Jankowski, 408 Mich. 79, 87, 289 N.W.2d 674 (1980), the Supreme Court reiterated the proposition that "[r]obbery has long been defined in this jurisdiction to be nothing more than a `larceny committed by assault or putting in fear.'" "When the taking is accomplished by force or assault, the offense is aggravated to one of robbery." Id. at 88, 289 N.W.2d 674.

With these principles in mind, I conclude that the Legislature did not intend that the armed robbery statute would permit a conviction absent an accomplished larceny. In 2004, the Legislature reworked Michigan's robbery statute, MCL 750.529, to read, in relevant part, as follows:

Concomitantly, the Legislature enacted a revised unarmed robbery statute, MCL 750.530, that described as follows the unlawful "conduct" referenced in § 529:

The majority holds that when the Legislature amended § 530 in 2004, it intended to eliminate a larcenous taking as a requisite element of a robbery. In the majority's opinion, "[t]he legislative definition of `in the course of committing a larceny' specifically `includes acts that occur in an attempt to commit the larceny,'" reflecting the Legislature's intent to punish both complete and incomplete larceny-related actions. Ante at 388.

When construing statutory language, which we review de novo, this Court must ascertain and give effect to the Legislature's intent. People v. Pasha, 466 Mich. 378, 382, 645 N.W.2d 275 (2002); People v. Hill, 269 Mich.App. 505, 514, 715 N.W.2d 301 (2006). "Because the Legislature is presumed to understand the meaning of the language it enacts into law, statutory analysis must begin with the wording of the statute itself." Robinson v. Detroit, 462 Mich. 439, 459, 613 N.W.2d 307 (2000); see also Pasha, 466 Mich. at 382, 645 N.W.2d 275 ("The first step in that determination is to review the language of the statute itself.") (quotation marks and citation omitted). In Bush v. Shabahang, 484 Mich. 156, 167-168, 772 N.W.2d 272 (2009), our Supreme Court offered this additional guidance regarding statutory interpretation:

Our Supreme Court has explained that the Legislature enacted the current version of the robbery statute in response to the Supreme Court's decision in People v. Randolph, 466 Mich. 532, 648 N.W.2d 164 (2002). In Randolph, the Supreme Court considered whether the robbery statute then in effect embraced the "transactional approach" to robbery, under which "a defendant has not completed a robbery until he has escaped with stolen merchandise. Thus, a completed larceny may be elevated to a robbery if the defendant uses force after the taking and before reaching temporary safety." Id. at 535, 648 N.W.2d 164. The Supreme Court in Randolph rejected the transactional approach, holding that under the common law the force or violence element of robbery "had to be applied before or during the taking." Id. at 538, 648 N.W.2d 164. When the Legislature subsequently amended the robbery statutes, it "explicitly stated that unarmed robbery is a transactional offense." People v. Morson, 471 Mich. 248, 265 n. 2, 685 N.W.2d 203 (2004) (CORRIGAN, C.J., concurring).

Distilled to its essence, the majority's position here is that, in addition to legislatively overruling Randolph, the Legislature's 2004 amendments to MCL 750.529 and MCL 750.530 also fundamentally altered the common-law underpinnings of the crime of robbery by eliminating the requirement of a completed larceny. But my analysis of the statutory language and the legislative history reveals no support for the majority's conclusion. Although the Legislature has the authority to abrogate the common law, "[w]hen it does so, it should speak in no uncertain terms." Hoerstman Gen. Contracting, Inc. v. Hahn, 474 Mich. 66, 74, 711 N.W.2d 340 (2006). Neither § 529 nor § 530 contains definite, clear, or plain language evincing the Legislature's intent to fundamentally alter the understanding of more than a century, that "[l]arceny is one of the essential elements of an armed robbery charge." LaTeur, 39 Mich.App. at 706, 198 N.W.2d 727.

Furthermore, the plain language of MCL 750.530 refutes that the amended robbery statutes permit conviction without proof of a completed larceny. Pursuant to § 530(1), a person who uses force or violence, puts in fear, or assaults another "in the course of committing a larceny" is guilty of a felony. Subsection 530(2) sets forth that the phrase "in the course of committing a larceny" includes "acts that occur in an attempt to commit the larceny, or during commission of the larceny, or in flight or attempted flight after the commission of the larceny, or in an attempt to retain possession of the property." Section 530 does not specifically define "in the course of," but according to Webster's New World Dictionary (2d college ed., 1970), "in the course of" means "in the progress or process of; during." Applying this meaning in the context of § 530, subsection 530(1) signifies that a person who uses force or violence at any point from the inception of the larceny until its conclusion is subject to prosecution for armed robbery. By elucidating in § 530 the "acts" constituting robbery, the Legislature intended to expand the temporal scope of the crime, transforming it into a transactional offense. Reading §§ 530(1) and (2) as a contextual whole, it appears that the Legislature sought to make clear that robbery encompasses acts that occur before, during, and after the larceny, not that the Legislature intended to eliminate larceny as an element of the crime. Nor does the legislative history suggest any purpose other than "to include any crime of larceny that involved the use of force or violence, or fear, at any time during the commission of the crime." House Legislative Analysis, HB 5105, February 12, 2004.

"Before accepting a guilty plea, a trial court must question the defendant to ascertain whether there is support for a finding that the defendant is guilty of the offense to which he is pleading guilty." People v. Watkins, 468 Mich. 233, 238, 661 N.W.2d 553 (2003). When questioning the defendant, the circuit court "must establish support for a finding that the defendant is guilty of the offense charged or to which the defendant is pleading." MCR 6.302(D)(1). Here, no evidence exists that defendant committed a larceny at Admiral Tobacco. Without evidence that defendant's actions at Admiral Tobacco included a larceny, I believe that the circuit court abused its discretion by denying defendant's motion to withdraw his guilty plea. Consequently, I would vacate defendant's conviction and sentence with regard to the Admiral Tobacco incident.1