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Name: People v. Corcoran
Case #: B180779
Court: CA Court of Appeal
District 2 DCA
Division: 4
Opinion Date: 09/22/2006

The appellate court rejected appellant’s argument that there was insufficient evidence to sustain kidnap convictions where appellant and his accomplice herded the victims of an aborted robbery approximately 10 feet from a public area to a small back windowless office, ripped the phone cord out of the wall, and threatened to shoot the victims if they left the office. There was substantial evidence that the movement of the victims was not merely incidental to the attempted robbery, and that the movement substantially increased the risk of harm to the victims. The movement of the victims had nothing to do with facilitating the taking of cash from the bingo hall; appellant had aborted that aim, and secluding the victims in the back office was clearly “excess and gratuitous.”