What is the force required to kidnap an individual in violation of Section 207 of the Criminal Code?

The United States also argues that, per Stokeling v. United States, 139 S.Ct. 544 (2019), the 924(e)(2) "force/elements clause" only requires the amount of force necessary to overcome a victim's resistance. The force required to kidnap an individual in violation of 207 is something more than the quantum of physical force necessary to affect the movement of the victim from one location to another, it is force enough to overcome the victim's free will. This understanding of 207 is consistent with Stokeling. Therefore, because 207 requires an amount of force that is sufficient to overcome a victim's resistance, it meets the 924(e)(2) force clause, and defense counsel was not ineffective for failing to argue to the contrary.