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Name: People v. Washington
Case #: B170486
Court: CA Court of Appeal
District 2 DCA
Division: 3
Opinion Date: 03/03/2005
Subsequent History: Revw. den. 6/15/05

During a bank robbery, appellant moved the bank manager from her office to the vault room, a distance of approximately 25 feet, and forced her to open the vault with the assistance of a teller who moved 15 feet to the vault. On appeal, appellant argued that the evidence was insufficient to support the conviction for kidnap for the purpose of robbery. The appellate court agreed, finding that the brief movement of the manager and teller to the bank’s vault room was incidental to the robbery and thus was insufficient to support a conviction of kidnap for the purpose of robbery. The fact that thresholds within the business are crossed cannot elevate robbery to aggravated kidnap, given that all of the movement occurred within close proximity to where the robbery commenced.