9th Cir. Model Jury Instr. (Criminal) 17.1

The defendant is charged in [Count _______ of] the indictment with kidnapping in violation of Section 1201(a)(1) of Title 18 of the United States Code. For the defendant to be found guilty of that charge, the government must prove each of the following elements beyond a reasonable doubt:

First, the defendant [seized] [confined] [inveigled] [decoyed] [kidnapped] [abducted] [carried away] [name of kidnapped person];

Second, the defendant [held] [detained] [name of kidnapped person] against [his] [her] [other pronoun] will; and

[Third, the defendant intentionally transported [name of kidnapped person] across state lines]

or

[Third, the defendant traveled in [interstate][foreign] commerce [in

committing] [in furtherance of committing] the offense] .

or

[Third, the defendant used [[the mail] [any [means] [facility] [instrumentality] of [interstate][foreign] commerce]] [[in committing] [in furtherance of committing]] the offense].

[The government is not required to prove that the defendant kidnapped [name of kidnapped person] for reward or ransom, or for any other purpose.]

[The fact that [name of kidnapped person] [may have] initially voluntarily accompanied the defendant does not necessarily [prevent the occurrence] [negate the existence] of a later kidnapping.]

To “kidnap” a person means to unlawfully hold, keep, detain, or confine the person

against their will and without their consent. Involuntariness or coercion in connection with the

victim’s detention is an essential part of the offense.

[To “inveigle” a person means to lure, entice or lead the person astray by false representations, promises, or other deceitful means.]