California, United States of America
The following excerpt is from People v. Curtis, G043681, Super. Ct. No. 07NF2542 (Cal. App. 2011):
using force or instilling a reasonable fear; (3) using that force or fear, the defendant made the other person move a substantial distance; (4) the other person was made to move a distance beyond that incidental to the commission of the robbery; (5) the defendant intended to commit robbery when the movement began; and (6) the other person did not consent to the movement. (See People v. Rayford (1994) 9 Cal.4th 1, 11-14.)
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