California, United States of America
The following excerpt is from People v. Stringer, B231835 (Cal. App. 2013):
of physical harm, this requirement can also be satisfied by a risk of mental, emotional, or psychological harm. (People v. Leavel (2012) 203 Cal.App.4th 823, 833-834; People v. Nguyen (2000) 22 Cal.4th 872, 885-886.)
E. Movements of victims here increased harm and was not incidental
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