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Hawai’i Supreme Court Announces Degree of ‘Restraint’ Necessary to Support Kidnapping Conviction

by Douglas Ankney

The Supreme Court of Hawai’i held that the restraint necessary to support a kidnapping conviction under Hawai’i Revised Statutes (“HRS”) § 707-720(1)(d) must be restraint that is “in excess of any restraint incidental to the infliction or intended infliction of bodily injury or subjection or intended subjection ...

 

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