State v. Lang

In State v. Lang, 164 Vt. 598, 664 A.2d 267 (1995), the Court found that because certain factors existed which enabled the assailant to accomplish the confinement through threats and intimidation, those factors contributed to the finding that despite a brief period of confinement, there was sufficient evidence to support a kidnapping conviction. 164 Vt. at 598-99, 664 A.2d at 268. In that case, evidence sufficient to support kidnapping conviction where defendant accosted frail, elderly victim at night, in her own home, wearing a ski mask, while demanding money of her, and refusing to let her leave her bedroom.