ICJI 1231B

ICJI 1231B SECOND DEGREE KIDNAPPING

In order for the defendant to be guilty of Kidnapping, the state must prove each of the following:

1. On or about [date]

2. in the state of Idaho

[[3. the defendant [name] [seized] [confined] [inveigled] [or] [kidnapped] [name of victim]

4. with the intent to cause [him] [her], without authority of law, [to be secretly [confined] [or] [imprisoned] within this state] [or] [to be sent out of this state] [or] [to be in any way [held to service] [or] [kept] [or] [detained] against [his] [her] will].]

[or]

[3. the defendant [name] [led] [took] [enticed away] [or] [detained] [name of victim]

4. a child under the age of 16 years

5. with the intent [to keep or conceal [the child] from [his] [her] [custodial parent] [guardian] [or] [a person having lawful care or control of the child]] [or] [to steal any article upon the person of the child].]

[or]

[3. the defendant [name] [abducted] [enticed] [or] [by force or fraud unlawfully took or carried away] [name of victim]

4. at or from a place outside the state of Idaho

5. and afterwards [sent] [brought] [had] [or] [kept] [him] [her] [or] [caused [him] [her] to be kept or secreted within the state of Idaho.]

[or]

[3. the defendant [name] [seized] [confined] [inveigled] [led] [took] [enticed away] [or] [kidnapped] [name of victim]

4. against [his] [her] will

5. with the intent to [extort [money] [property] [or] [any thing of value]] [or] [obtain [money] [property] [reward] [or] [any thing of value]] for [his] [her] return or disposition.]],

If any of the above has not been proved beyond a reasonable doubt, you must find the defendant not guilty. If each of the above has been proven beyond a reasonable doubt, then you must find the defendant guilty.

Comment

I.C. � 18-4501.