State v. Ward
Annotate this CaseA jury found Defendant guilty of sexual assault in the first degree and kidnapping in the first degree. The trial court granted Defendant's motion for judgment of acquittal on the kidnapping charge on the ground that the State had failed to prove beyond a reasonable doubt that Defendant intended to prevent the liberation of the victim for a longer period of time or to a greater degree than that which was necessary to commit the sexual assault as required by State v. Salamon. The Supreme Court reversed the judgment of the trial court as to the kidnapping charge, holding (1) the trial court improperly improperly granted Defendant's motion for judgment of acquittal and rendered judgment of not guilty on the kidnapping charge, as the jury reasonably could have concluded that Defendant's restraint of the victim was not merely incidental to the sexual assault; (2) the judgment may not be affirmed on the alternate ground that the kidnapping statute, as applied to Defendant's conduct, was unconstitutionally vague; and (3) the trial court's instruction on the kidnapping charge was not misleading. Remanded.
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