State v. Jolivet
In State v. Jolivet, 712 P.2d 843 (Utah 1986), the defendant forced the victim at gunpoint to enter his car in a store parking lot.
He then drove the victim to a separate location where he sexually assaulted her, still at gunpoint. After the assault, the defendant forced the victim to remain with him while returning to the store.
Upon returning, the victim was released only after promising the defendant to go later to Canada with him. See id. at 844.
Jolivet held that the evidence established that "a sufficiently substantial period of time elapsed, both before and after the assault and rape, in which the victim was restrained against her will and subjected to a substantial risk of harm from the defendant's threats and loaded gun." Id.
The Court concluded that "the evidence sufficiently supports the charge of aggravated kidnaping as an act separate from the other charges." Id.