California, United States of America
The following excerpt is from People v. Williams, 220 Cal.App.3d 1165, 269 Cal.Rptr. 705 (Cal. App. 1990):
Defendant initially challenges the evidence as being insufficient to establish movement "for a substantial distance." As People v. Stanworth (1974) 11 Cal.3d 588, 600-601, 114 Cal.Rptr. 250, 522 P.2d 1058 makes clear, the rule requiring movement not merely incidental to associated [220 Cal.App.3d 1171] crimes and a substantial increase in the risk of harm for section 209 kidnaping does not apply to section 207 simple kidnaping. What is required is a "substantial movement" of the victim which is more than slight or trivial. (Id., at p. 601, 114 Cal.Rptr. 250, 522 P.2d 1058.)
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