The Advisory Committee on Criminal Jury Instructions revised CC 1600 in August, 2009, and stated:
The committee revised [CC No. 1600], Robbery, after the Supreme Court rendered its opinion in People v. Scott (2009) 45 Cal. 4th 743. The Scott case found that an employee on duty has constructive possession of the employer’s property during a robbery.
CC 1600 now provides that “A (store/[or] business) (employee___<insert description> who is on duty has possession of the (store/[or] business) owner’s property.