In People v. Hill (2000) 23 Cal. 4th 853, a seven-month-old baby and her mother were abducted in a car and transported to a location where the defendant and his accomplice forced the mother to perform sexual acts. The accomplice threatened to shoot the baby if the mother did not cooperate. (People v. Hill, supra, 23 Cal. 4th at pp. 855, 858.) Hill was convicted of kidnapping and carjacking. (Id., at p. 855.) He argued that the Supreme Court should overturn his kidnapping conviction because "his illegal intent was directed at the mother, not the child." (Id. at p. 858.) The Supreme Court disagreed and adopted the appellate court's language: " 'Even if we assume the movement of the child might not have been a means to commit a crime directly against her, it was, however, carried out as the direct result of the intent to commit a crime and, within the reasoning of Oliver, renders defendant liable for the baby's kidnapping . . . .' " (Ibid.) In Hill, the Supreme Court also interpreted the carjacking statute ( 215, subd. (a)), a necessarily included offense within a kidnapping-for-carjacking charge. (See People v. Contreras (1997) 55 Cal. App. 4th 760 64 Cal. Rptr. 2d 233.) The court expanded the holding from the Oliver kidnapping case: "A similar rule should apply to carjacking, except that there need be no separate requirement of an illegal purpose. Unlike kidnapping, if the remaining elements of carjacking are present, an illegal purpose will always exist . . . . Accordingly, for carjacking, a taking will be considered against the 'will' of an infant if it is without lawful consent." (People v. Hill, supra, 23 Cal. 4th at p. 860.) The court indicated that it did not have to inquire "whether, or to what extent the Oliver decision eliminated the need to show as to a child force or fear in addition to an illegal purpose, or whether the illegal purpose itself establishes force or fear," it did make the following observations: "At the least, our decision in Oliver 'indicated that in kidnapping cases the requirement of force may be relaxed where the victim is a minor who is "too young to give his legal consent to being taken" and the kidnapping was done for an improper purpose.' "As with kidnapping, an analytical problem arises when the victim is an infant. But we do not believe the solution is to conclude that an infant, lacking an independent will cannot be the victim of a carjacking. . . .When applied to an infant, we believe that what the Legislature most likely meant by 'against his or her will' was merely the absence of lawful consent, not an affirmative act of free will. The Oliver decision, concerning kidnapping's analogous, if implied, requirement that the victim's free will be overborne, points the way. Oliver did not require an affirmative showing that the taking was against the child's will. It sufficed if the taking was for an unlawful purpose." (People v. Hill, supra, 23 Cal. 4th 853 at pp. 859-860.) The Court concluded that there was "ample evidence of force or fear" in Hill because the defendants had forced the woman and her child to accompany them in the car, and had driven the car with both the woman and the child inside of it. (Hill, supra, 23 Cal.4th at p. 857.) "Here, defendant snatched the baby as well as the mother. The baby certainly did not move herself. Dabney also threatened to shoot the baby, thus using her as leverage to force the mother's cooperation. Additionally, the car seat was unbuckled, and Marissa the baby was rolling around on the front seat while defendant drove. We are unaware of any authority that to suffer kidnapping, a baby must apprehend any force used against her." (Hill, at pp. 857-858.) Because the force or fear requirement was satisfied in Hill, it was not necessary for the court to decide whether People v. Oliver (1961) had eliminated the force or fear requirement where the victim " 'by reason of immaturity or mental condition is unable to give his legal consent' " to the movement. (Hill, at p. 857.) "We need not, and do not, decide whether, or to what extent, the Oliver decision eliminated the need to show as to a child force or fear in addition to an illegal purpose, or whether the illegal purpose itself establishes force or fear , for here ample evidence of force or fear exists." (Ibid.) Nevertheless, the court suggested in Hill that Oliver had "relaxed" the force requirement. "At the least, our decision in Oliver 'indicated that in kidnapping cases the requirement of force may be relaxed where the victim is a minor who is "too young to give his legal consent to being taken" and the kidnapping was done for an improper purpose.' " (Ibid.)