There is no requirement of stealth actions.
Duh, armed robbery is not very stealth..
Here’s a typical statute (stealth is one way to rob, but there are other ways obviously):
ยง 22-2801. Robbery. | D.C. Law Library
Whoever by force or violence, whether against resistance or by sudden or stealthy seizure or snatching, or by putting in fear, shall take from the person or immediate actual possession of another anything of value, is guilty of robbery, and any person convicted thereof shall suffer imprisonment for not less than 2 years nor more than 15 years.
https://codes.ohio.gov/ohio-revised-code/section-2911.12
The above is for burglary.
That judge is being too cute by half.