California Penal Code Section 207 - Example Case
In People v. Martinez (1999) 20 Cal.4th 225, 235-237, the Supreme Court rejected the measure of "substantial" movement used in past kidnapping cases.
The court reaffirmed that the movement must be substantial in character, but it replaced distance as the "sole criterion for assessing asportation" in simple kidnapping (section 207 violations) with consideration of the totality of the circumstances, including not only the number of feet or yards the victim is moved but also, where relevant, contextual factors such as "whether that movement increased the risk of harm above that which existed prior to the asportation, decreased the likelihood of detection, and increased both the danger inherent in a victim's foreseeable attempts to escape and the attacker's enhanced opportunity to commit additional crimes." (20 Cal.4th at p. 237.)