Doud v. State
In Doud v. State, 845 P.2d 402, 405-07 (Wyo. 1993), the Court compared the two crimes, but we did not address the specific issue of whether false imprisonment is a lesser-included offense of kidnapping. Although the Court referred to false imprisonment as a "lesser offense," the Court did not deal directly with the fact that the jury in Doud was instructed that false imprisonment was a lesser-included offense of kidnapping. Id.
Instead, the focus was on the elements of kidnapping that distinguish it from false imprisonment and felonious restraint.
In that regard, the Court noted that kidnapping, unlike false imprisonment or felonious restraint, contains the element of confinement with the intent to hold for ransom, to facilitate the commission of a felony, to inflict bodily injury on, or to terrorize the victim. Id. at 406.