How have courts interpreted section 209.5 of the California Criminal Code regarding kidnapping during the commission of a carjacking?

Defendant contends People v. Perez (2000) 84 Cal.App.4th 856 (Perez) supports his position. We disagree. The section 209.5 holding in Perez supports the Attorney General, not defendant. The defendant there and another man approached the victim of the carjacking and demanded his keys and money. The victim gave them his keys and wallet, and they drove away with him in the car, telling him they would go to his house. (Id. at p. 859.) The defendant was convicted of both kidnapping during the commission of a carjacking ( 209.5) and kidnapping during the commission of a robbery ( 209). (Id. at p. 858.) On appeal, the defendant contended the kidnapping was not intended to "facilitate" the carjacking because, since he and the other man already had the car keys, the kidnapping did not make removal of the car any easier. (Id. at p. 860.) Our colleagues in Division Two of this court rejected this "myopic view of the word 'facilitate,' " concluding that "if there is substantial evidence that appellant intended the kidnapping to effect an escape or prevent an alarm from being sounded, his conviction for kidnapping during the commission of a carjacking must stand." (Id. at pp. 860-861.) In the case before us, the carjacking similarly allowed defendant to escape. Moreover, if anything, the facts here even more strongly support a section 209.5 conviction because, here, defendant had Doe drive the car, thus facilitating his crime.