United States v. Chapman — Ninth Circuit: Federal Kidnapping Can Be Committed by Deception, But Conviction Vacated for Jury Coercion
The Ninth Circuit holds that federal kidnapping under 18 U.S.C. 1201(a)(1) can be committed by deception alone, but vacates the murder-kidnapping conviction because the trial judge improperly coerced a unanimous verdict from a deadlocked jury.