In People v. Reyes Martinez (1993) 14 Cal.App.4th 1412, the defendant was charged with kidnapping. The jury was correctly instructed that an element of the crime was the victim was moved a substantial distance. The jury was then instructed, however, that if the jury found the victim was forcibly moved a distance of 500 feet or more, the movement was sufficiently substantial to allow a conviction for kidnapping. The court concluded such instruction an unconstitutional conclusive presumption. ( Id. at pp. 1417-1418.)