People v. Kozlowski

In People v. Kozlowski (2002) 96 Cal.App.4th 853, the Court of Appeal held that a personal identification number (PIN) associated with an automated teller machine card constitutes property for purposes of kidnapping for extortion. In reaching this conclusion, the court reasoned that the term "property" should be broadly interpreted for purposes of extortion. (Id. at pp. 865-866.) "The term is all-embracing, including every intangible benefit and prerogative susceptible of possession or disposition." (Id. at p. 866.) The Kozlowski court reasoned that a PIN code, a number that operates as a means of account access, is intangible property because the code is exclusively possessed and allows the possessor to access funds in a related bank account. (Kozlowski, at p. 867.)