Hargrove v. State

Phipps, Judge.

Daniel Hargrove was tried by a jury and convicted of kidnapping with bodily injury, family violence aggravated battery and two counts of family violence aggravated assault. On appeal, he claims that the evidence was insufficient to support his kidnapping conviction and that the trial judge erred in failing to sua sponte recuse himself when the victim, Sabine Payton, indicated that the judge had been involved when she obtained a temporary protective order. Finding the evidence insufficient to establish the asportation element of kidnapping, we reverse Hargrove’s conviction for…