How have the courts interpreted Section 209(a) of the aggravated kidnapping statute?

^21. The people assert that while the statute addresses four different types of aggravated kidnapping, the jury was instructed on only the third typekidnapping for extortion. Although the written jury instruction was entitled "Kidnapping For Extortion (Pen. Code, 209(a))" the wording of the instruction included the fourth type of kidnappingkidnapping to exact from another person any money or valuable thing. However, since as we have explained, the jury was only given the option of finding kidnapping for extortion, we must assume that the jury ignored the "or to get money or something valuable" language. (See People v. McKinnon (2011) 52 Cal.4th 610, 670 [reviewing court presumes jurors are intelligent and possess common sense].)