State v. Fields
Annotate this CaseAfter a jury trial, Defendant was convicted of two counts of kidnapping in the second degree and one count of risk of injury to a child. The Supreme Court reversed the judgment of the trial court as to one of the two kidnapping counts and remanded for a new trial on that charge, holding (1) Defendant was entitled to a jury instruction in accordance with State v. Salamon, which bars a jury from finding a defendant guilty of kidnapping if it finds that the restraint used in connection therewith was merely incidental to the restraint used in the commission of another offense, and (2) the trial court's failure to give such an instruction was not harmless beyond a reasonable doubt. The Supreme Court affirmed the trial court's judgment in all other respects.
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