Kidnapping Sexual Abuse Case In Iowa
"Confinement," for the purposes of Iowa kidnapping statute, requires more than a confinement or removal that is merely an incident of the commission of sexual abuse. State v. Ristau, 340 N.W.2d 273, 275 (Iowa 1983).
No minimum period of confinement or distance of removal is required, but it must exceed what is normally incidental to the commission of the sexual abuse. State v. Wilcoxen, 549 N.W.2d 304, 306 (Iowa App. 1996). In addition, the confinement or removal must have significance independent from the act of sexual abuse itself in one of the following ways:
(a) substantially increase the risk of harm to the victim;
(b) significantly lessen the risk of detection;
(c) significantly facilitate escape following the consummation of the sex abuse offense. Id.