United States v. Robert Ford
United States Court of Appeals for the Eighth Circuit
726 F.3d 1028 (2013)
Robert Ford (defendant) was prosecuted for sexually abusing Christina Weston, his former girlfriend, and for kidnapping her by confining her afterward; Weston testified, corroborated by DNA evidence and two other witnesses, that after the assault Ford barricaded her in her bedroom and took her phone to prevent her from reporting it. The jury was instructed it could convict on kidnapping without also finding sexual assault, and it acquitted Ford of sexual abuse but convicted him of kidnapping; he appealed, arguing his acquittal on sexual assault required acquittal on kidnapping as a matter of law.
Whether one element of the federal kidnapping statute is that the defendant held his victim for ransom, reward, or otherwise.