California, United States of America
The following excerpt is from People v. Ordonez, 226 Cal.App.3d 1207, 277 Cal.Rptr. 382 (Cal. App. 1991):
12 Although we analyze section 209, subdivisions (a) and (b) as separate crimes, we believe aggravated kidnapping for ransom, extortion or reward is a single crime, even though the offense may be committed in a large number of ways (e.g. seizing, confining, inveigling) and for any one of several related purposes (e.g. for ransom, reward or to commit extortion). (See People v. Henderson (1977) 19 Cal.3d 86, 93, 137 Cal.Rptr. 1, 560 P.2d 1180 [similar analysis based upon false imprisonment statute, 237].) Each of these forms of the aggravated offense shares the single primary element of deprivation of a person's liberty in order to extract a financial gain.
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