Is kidnapping for robbery a form of aggravated kidnapping defined in section 209 of the California Criminal Code?

Kidnapping for robbery is one of the varieties of aggravated kidnapping defined in section 209, subdivision (b)(1), which states: "Any person who kidnaps or carries away any individual to commit robbery . . . shall be punished by imprisonment in the state prison for life with the possibility of parole." Subdivision (b)(2) of section 209 states: "This subdivision shall only apply if the movement of the victim is beyond that merely incidental to the commission of, and increases the risk of harm to the victim over and above that necessarily present in, the intended underlying offense." Thus, kidnapping for robbery requires "movement of the victim that is not merely incidental to the commission of the robbery, and which substantially increases the risk of harm over and above that necessarily present in the crime of robbery itself." (People v. Rayford (1994) 9 Cal.4th 1, 12 (Rayford).)

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