In People v. Moya (1992) 4 Cal.App.4th 912, the court concluded the definition of kidnapping encompasses any asportation accomplished by fear. The court noted the then recent amendment to the definition of kidnapping in section 207. It noted that prior to 1990, section 207 required a forcible taking. In 1990 the Legislature added to the section the language "or by any other means of instilling fear." (Ibid.) The appellant in Moya argued this amendment required that the use of force must actually instill fear. The court in Moya responded: "We do not interpret the statute as now requiring an additional element before a conviction of kidnapping can be sustained. Prior to the amendment, kidnapping could only be sustained upon a finding that the person was taken . . . by the use or threat of force. If a person's free will was not overborne by the use of force or the threat of force, there was no kidnapping. As we read the amended version of section 207, kidnapping can now be accomplished not only by the application of force or threats of force but also by other methods which instill fear. Rather than modifying and defining (and thereby limiting) the word 'forcibly'. . ., the phrase 'by any other means of instilling fear' expands the types of methods by which a person can overcome the free will of his or her victim. Thus, rather than being an additional element for the crime of kidnapping, the new language provides an alternative basis for finding a defendant guilty of kidnapping." (People v. Moya, supra, 4 Cal.App.4th at pp. 916-917.)