People v. Daniels

Opinion

KING, J.

In this case we hold that when the defendant forced his victim to go from a public area to a less frequented nearby location, robbed him, and, upon discovering the victim possessed a bank card, required him to accompany defendant to a bank to withdraw cash from an automated teller machine, the defendant was properly convicted of kidnapping 1 for robbery. Although scholarly opinion has been consistent in answering the question of what conduct constitutes kidnapping for robbery as opposed to robbery alone, judicial application of the rule has varied considerably as courts…