unlawful violation in California

2000“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; accord, People v. Fosselman (1983) 33 Cal.3d 572, 579 [ 189 Cal.Rptr. 855 , 659 P.2d 1144 ]; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 [ 13 Cal.Rptr.2d 62 ] (Von Villas).) In this context, “ ‘[p]ersonal liberty’ ” is violated when “the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (Von Villas, supra, 10 Cal.App.4th at p. 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 [ 142 Cal.Rptr. 186 ]; accord, People v. Agnew (1940) 1

2000“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; accord, People v. Fosselman (1983) 33 Cal.3d 572, 579 [ 189 Cal.Rptr. 855 , 659 P.2d 1144 ]; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 [ 13 Cal.Rptr.2d 62 ] (Von Villas).) In this context, “ ‘[p]ersonal liberty’ ” is violated when “the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (Von Villas, supra, 10 Cal.App.4th at p. 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 [ 142 Cal.Rptr. 186 ]; accord, People v. Agnew (1940) 1

2024Defendant claims the trial court should have instructed on misdemeanor false imprisonment as a lesser included offense to those counts because there was substantial evidence to conclude that the imprisonment was effected without “violence” or “menace.” False imprisonment is “the unlawful violation of the personal liberty of another.” (§ 236.) “The misdemeanor offense requires no force beyond that necessary to restrain the victim.” (People v. Babich (1993) 14 Cal.App.4th 801, 806 .) Misdemeanor false imprisonment becomes a felony if the imprisonment is effected with the use of violence, menace,

2023Applicable Law “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; see People v. Jennings (2010) 50 Cal.4th 616, 638-639 ; People v. Reed (2000) 78 Cal.App.4th 274, 280 .) In this context, “ ‘[p]ersonal liberty’ is violated when the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (People v. Von Villas (1992) 10 Cal.App.4th 201, 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 .) “If the false imprisonment be effected by violence, menace, fraud, or deceit, it shall be punishable by impri

2016“False imprisonment is the unlawful violation of the personal liberty of another. (§ 236.) The crime of false imprisonment requires some intended confinement or restraint of the person; any exercise of force or express or implied threat of force by which in fact the person is restrained from his liberty, compelled to remain where he does not wish to remain, or to go where he does not wish to go, is such imprisonment. [Citation.] The imprisonment may be committed by acts or words said or done with the intent of causing the confinement. [Citation.] [¶] An attempt to commit a crime consists of a

2013Substantial Evidence Supports the Jury’s Finding of Felony False Imprisonment “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) It occurs when the defendant intentionally restrains, confines or detains another person without his or her consent for “‘“an appreciable length of time, however short.”’” (Fermino v. Fedco, Inc. (1994) 7 Cal.4th 701, 715 ; see ibid. [“The crime of false imprisonment is defined by [§] 236 as the ‘unlawful violation of the personal liberty of another.’ The tort is identically defined.”].) When the restraint on the victim’s pers

2000"False imprisonment is the unlawful violation of the personal liberty of another." (§ 236; accord People v. Fosselman (1983) 33 Cal.3d 572, 579 , 189 Cal.Rptr. 855 , 659 P.2d 1144 ; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 , 13 Cal.Rptr.2d 62 ( Von Villas ).) In this context, "`[personal liberty'" is violated when "the victim is `compelled to remain where he does not wish to remain, or to go where he does not wish to go.'" ( Von Villas, supra, 10 Cal. App.4th at p. 255 , 13 Cal.Rptr.2d 62 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 , 142 Cal.Rptr. 186 ; accord People v.

2000"False imprisonment is the unlawful violation of the personal liberty of another." (§ 236; accord People v. Fosselman (1983) 33 Cal.3d 572, 579 , 189 Cal.Rptr. 855 , 659 P.2d 1144 ; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 , 13 Cal.Rptr.2d 62 ( Von Villas ).) In this context, "`[personal liberty'" is violated when "the victim is `compelled to remain where he does not wish to remain, or to go where he does not wish to go.'" ( Von Villas, supra, 10 Cal. App.4th at p. 255 , 13 Cal.Rptr.2d 62 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 , 142 Cal.Rptr. 186 ; accord People v.

2000“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; accord, People v. Fosselman (1983) 33 Cal.3d 572, 579 [ 189 Cal.Rptr. 855 , 659 P.2d 1144 ]; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 [ 13 Cal.Rptr.2d 62 ] (Von Villas).) In this context, “ ‘[p]ersonal liberty’ ” is violated when “the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (Von Villas, supra, 10 Cal.App.4th at p. 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 [ 142 Cal.Rptr. 186 ]; accord, People v. Agnew (1940) 1

2000“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; accord, People v. Fosselman (1983) 33 Cal.3d 572, 579 [ 189 Cal.Rptr. 855 , 659 P.2d 1144 ]; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 [ 13 Cal.Rptr.2d 62 ] (Von Villas).) In this context, “ ‘[p]ersonal liberty’ ” is violated when “the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (Von Villas, supra, 10 Cal.App.4th at p. 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 [ 142 Cal.Rptr. 186 ]; accord, People v. Agnew (1940) 1

2025Legal Principles “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) “In this context, ‘ “[p]ersonal liberty” ’ is violated when ‘the victim is “compelled to remain where [they do] not wish to remain, or to go where [they do] not wish to go.” ’ [Citations.]” (People v. Reed (2000) 78 Cal.App.4th 274, 280 .) “If the false imprisonment be effected by violence, menace, fraud, or deceit, it shall be punishable by imprisonment pursuant to subdivision (h) of Section 1170.” (§ 237.) “Misdemeanor false imprisonment is a lesser and necessarily included offense of

2025Legal Principles “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) “In this context, ‘ “[p]ersonal liberty” ’ is violated when ‘the victim is “compelled to remain where [they do] not wish to remain, or to go where [they do] not wish to go.” ’ [Citations.]” (People v. Reed (2000) 78 Cal.App.4th 274, 280 .) “If the false imprisonment be effected by violence, menace, fraud, or deceit, it shall be punishable by imprisonment pursuant to subdivision (h) of Section 1170.” (§ 237.) “Misdemeanor false imprisonment is a lesser and necessarily included offense of

2024Defendant claims the trial court should have instructed on misdemeanor false imprisonment as a lesser included offense to those counts because there was substantial evidence to conclude that the imprisonment was effected without “violence” or “menace.” False imprisonment is “the unlawful violation of the personal liberty of another.” (§ 236.) “The misdemeanor offense requires no force beyond that necessary to restrain the victim.” (People v. Babich (1993) 14 Cal.App.4th 801, 806 .) Misdemeanor false imprisonment becomes a felony if the imprisonment is effected with the use of violence, menace,

2000"False imprisonment is the unlawful violation of the personal liberty of another." (§ 236; accord People v. Fosselman (1983) 33 Cal.3d 572, 579 , 189 Cal.Rptr. 855 , 659 P.2d 1144 ; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 , 13 Cal.Rptr.2d 62 ( Von Villas ).) In this context, "`[personal liberty'" is violated when "the victim is `compelled to remain where he does not wish to remain, or to go where he does not wish to go.'" ( Von Villas, supra, 10 Cal. App.4th at p. 255 , 13 Cal.Rptr.2d 62 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 , 142 Cal.Rptr. 186 ; accord People v.

2010Elements of False Imprisonment “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) False imprisonment is a felony if “effected by violence, *1357 menace, fraud, or deceit. . . .” (§ 237, subd. (a); People v. Fernandez (1994) 26 Cal.App.4th 710, 717 [ 31 Cal.Rptr.2d 677 ].) “ ‘Force is an element of both felony and misdemeanor false imprisonment.

2010Elements of False Imprisonment “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) False imprisonment is a felony if “effected by violence, *1357 menace, fraud, or deceit. . . .” (§ 237, subd. (a); People v. Fernandez (1994) 26 Cal.App.4th 710, 717 [ 31 Cal.Rptr.2d 677 ].) “ ‘Force is an element of both felony and misdemeanor false imprisonment.

2024(People v. Castro (2006) 138 Cal.App.4th 137, 140 (Castro).) Misdemeanor false imprisonment, which is a lesser included offense of felony false imprisonment (People v. Babich (1993) 14 Cal.App.4th 801, 806 ), becomes a felony “only where the force used is greater than that reasonably necessary to effect the restraint.

2016(Id., at pp. 149, 164; People v. Watson (1956) 46 Cal.2d 818, 836 .) Reversal is warranted under that standard if "it appears 'reasonably probable' the defendant would have achieved a more favorable result had the error not occurred." (Ibid.) "False imprisonment is the unlawful violation of the personal liberty of another." (§ 236.) "[F]alse imprisonment of an elder or a dependent adult by the use of violence, menace, fraud, or deceit" is a felony. (§ 368, subd. (f).) 3 Similarly, the use of violence, menace, fraud, or deceit elevates false imprisonment to a felony. (§ 237, subd. (a); People v

1960As the court says in Neves v. Costa (1907), 5 Cal.App. 111, 117-118 [ 89 P. 860 ], ‘ “False imprisonment is the unlawful violation of the personal liberty of another” (Pen.

1960As the court says in Neves v. Costa (1907), 5 Cal.App. 111, 117-118 [ 89 P. 860 ], ‘ “False imprisonment is the unlawful violation of the personal liberty of another” (Pen.

2015He argues that the evidence was insufficient to support this conviction because there was insufficient evidence that he restrained Nichols or forced her to stay or go anywhere against her will. 10 “As defined in section 236, ‘False imprisonment is the unlawful violation of the personal liberty of another.’ Without more, the conduct described in section 236 is a misdemeanor offense. (§ 237.) If effectuated by ‘violence, menace, fraud or deceit,’ false imprisonment is elevated to a felony. (§ 237.)” (People v. Henderson (1977) 19 Cal.3d 86, 93 , overruled on another ground in People v. Flood (19

2014“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) False imprisonment “effected by violence” is a felony. (§ 237, subd. (a).) Citing People v. Henderson (1977) 19 Cal.3d 86 (Henderson), overruled on other grounds in People v. Flood (1998) 18 Cal.4th 470, 484, 490 , Viens asserts that, as a matter of law, felony false imprisonment is not inherently dangerous to human life, and it thus can support a conviction of involuntary manslaughter if committed without due caution and circumspection.

2023Defendant pleaded no contest to felony false imprisonment of his daughter, which is defined as “the unlawful violation of the personal liberty of another.” (§ 236.) While defendant’s reply brief asserts that the record does not indicate the means by which defendant effected the felony false imprisonment, the first amended complaint specifically charged defendant with false imprisonment “being effected by menace,” and defendant likewise acknowledged in an advisement of rights form that he agreed to plead guilty to false imprisonment “by menace.” “False imprisonment is a misdemeanor unless it is

2012“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) “False imprisonment is a misdemeanor unless it is ‘effected by violence, menace, fraud, or deceit,’ in which case it is a felony.” (People v. Wardell (2008) 162 Cal.App.4th 1484, 1490 [ 77 Cal.Rptr.3d 77 ], quoting § 237, subd. (a).) “All that is necessary to make out a charge of false imprisonment, a misdemeanor, is that ‘the individual be restrained of his liberty without any sufficient complaint or authority therefor, and it may be accomplished by words or acts [together with the requisite intent to

2024Defendant claims the trial court should have instructed on misdemeanor false imprisonment as a lesser included offense to those counts because there was substantial evidence to conclude that the imprisonment was effected without “violence” or “menace.” False imprisonment is “the unlawful violation of the personal liberty of another.” (§ 236.) “The misdemeanor offense requires no force beyond that necessary to restrain the victim.” (People v. Babich (1993) 14 Cal.App.4th 801, 806 .) Misdemeanor false imprisonment becomes a felony if the imprisonment is effected with the use of violence, menace,

2021“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) False imprisonment is punishable as a felony where it is “effected by violence, menace, fraud, or deceit.” (§ 237, subd. (a).) As the commentary for CALCRIM No. 1240 explains, “[f]orce is required for a finding of both misdemeanor and felony false imprisonment, while violence is only required for the felony.” And “[v]iolence means using physical force that is greater than the force reasonably necessary to restrain someone.” (CALCRIM No. 1240; see People v. Hendrix (1992) 8 Cal.App.4th 1458, 1462 .) “Whe

2023Applicable Law “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; see People v. Jennings (2010) 50 Cal.4th 616, 638-639 ; People v. Reed (2000) 78 Cal.App.4th 274, 280 .) In this context, “ ‘[p]ersonal liberty’ is violated when the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (People v. Von Villas (1992) 10 Cal.App.4th 201, 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 .) “If the false imprisonment be effected by violence, menace, fraud, or deceit, it shall be punishable by impri

2014(See § 207, subd. (a) [“[e]very person who forcibly, or by any other means of instilling fear, steals or takes, or holds, detains, or arrests any person in this state and carries the person into another country, state, or county, or into another part of the same county, is guilty of kidnapping”].) Simple kidnapping essentially has three elements: “‘(1) a person was unlawfully moved by the use of physical force or fear; (2) the movement was without the person’s consent; and (3) the movement of the person was for a substantial distance.’” (People v. Byrd (2011) 194 Cal.App.4th 88, 101 ; People v

2022(See People v. Chacon (1995) 37 Cal.App.4th 52, 65 [false imprisonment is a lesser included offense of kidnapping for ransom].) “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) “No asportation is required. ‘[K]idnapping, be it simple or aggravated, requires a degree of asportation not found in the definition of false imprisonment.

2021(See People v. Chacon (1995) 37 Cal.App.4th 52, 65 [false imprisonment is a lesser included offense of kidnapping for ransom].) “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) “No asportation is required. ‘[K]idnapping, be it simple or aggravated, requires a degree of asportation not found in the definition of false imprisonment.

2014(See § 207, subd. (a) [“[e]very person who forcibly, or by any other means of instilling fear, steals or takes, or holds, detains, or arrests any person in this state and carries the person into another country, state, or county, or into another part of the same county, is guilty of kidnapping”].) Simple kidnapping essentially has three elements: “‘(1) a person was unlawfully moved by the use of physical force or fear; (2) the movement was without the person’s consent; and (3) the movement of the person was for a substantial distance.’” (People v. Byrd (2011) 194 Cal.App.4th 88, 101 ; People v

2000“False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236; accord, People v. Fosselman (1983) 33 Cal.3d 572, 579 [ 189 Cal.Rptr. 855 , 659 P.2d 1144 ]; People v. Von Villas (1992) 10 Cal.App.4th 201, 255 [ 13 Cal.Rptr.2d 62 ] (Von Villas).) In this context, “ ‘[p]ersonal liberty’ ” is violated when “the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” (Von Villas, supra, 10 Cal.App.4th at p. 255 , quoting People v. Haney (1977) 75 Cal.App.3d 308, 313 [ 142 Cal.Rptr. 186 ]; accord, People v. Agnew (1940) 1

2025(See People v. Ratcliffe (1981) 124 Cal.App.3d 808, 821 [“He who kidnaps a victim does so in order to restrain the personal liberty of his victim (Pen.

2022(See People v. Ratcliffe (1981) 124 Cal.App.3d 808, 821 [“He who kidnaps a victim does so in order to restrain the personal liberty of his victim (Pen.

2026Felony False Imprisonment Defendant also states he could have pled to felony false imprisonment “by menace, fraud or deceit,” in violation of sections 236 and 237, and it would have been an immigration-neutral conviction. “ ‘False imprisonment is the unlawful violation of the personal liberty of another.’ [Citation.] . . . ‘All that is necessary to make out a charge of false imprisonment, a misdemeanor, is that “the individual be restrained of his liberty without any sufficient complaint or authority therefor, and it may be accomplished by words or acts [together with the requisite intent to c

2025Legal Principles “False imprisonment is the unlawful violation of the personal liberty of another.” (§ 236.) “In this context, ‘ “[p]ersonal liberty” ’ is violated when ‘the victim is “compelled to remain where [they do] not wish to remain, or to go where [they do] not wish to go.” ’ [Citations.]” (People v. Reed (2000) 78 Cal.App.4th 274, 280 .) “If the false imprisonment be effected by violence, menace, fraud, or deceit, it shall be punishable by imprisonment pursuant to subdivision (h) of Section 1170.” (§ 237.) “Misdemeanor false imprisonment is a lesser and necessarily included offense of

2026Felony False Imprisonment Defendant also states he could have pled to felony false imprisonment “by menace, fraud or deceit,” in violation of sections 236 and 237, and it would have been an immigration-neutral conviction. “ ‘False imprisonment is the unlawful violation of the personal liberty of another.’ [Citation.] . . . ‘All that is necessary to make out a charge of false imprisonment, a misdemeanor, is that “the individual be restrained of his liberty without any sufficient complaint or authority therefor, and it may be accomplished by words or acts [together with the requisite intent to c

2023Defendant pleaded no contest to felony false imprisonment of his daughter, which is defined as “the unlawful violation of the personal liberty of another.” (§ 236.) While defendant’s reply brief asserts that the record does not indicate the means by which defendant effected the felony false imprisonment, the first amended complaint specifically charged defendant with false imprisonment “being effected by menace,” and defendant likewise acknowledged in an advisement of rights form that he agreed to plead guilty to false imprisonment “by menace.” “False imprisonment is a misdemeanor unless it is

2025Analysis “Although, ordinarily, a defendant ‘may be convicted of any number of offenses charged’ (§ 954), ‘a judicially created exception to this rule prohibits multiple convictions based on necessarily included offenses.’ ” (People v. Aranda (2019) 6 Cal.5th 1077, 1089 .) “An offense is necessarily included within another if ‘the statutory elements of the greater offense … include all the elements of the lesser offense….’ ” (People v. Lewis (2008) 43 Cal.4th 415, 518 , overruled on other grounds in People v. Black (2014) 58 Cal.4th 912, 919 .) False imprisonment—“ ‘the unlawful violation of t

2022False imprisonment is defined as “the unlawful violation of the personal liberty of another.” (§ 236.) False imprisonment occurs “ ‘when “the victim is ‘compelled to remain where he does not wish to remain, or to go where he does not wish to go.’ ” ’ ” (People v. Williams (2017) 7 Cal.App.5th 644, 672 .) “A defendant guilty of kidnapping, as defined by either section 207 or 209 …, must necessarily be guilty of the ‘unlawful violation of the personal liberty of’ his victim and therefore be guilty of false imprisonment as defined by section 236” (People v. Morrison (1964) 228 Cal.App.2d 707, 713

2024We review the entire record in the light most favorable to the judgment below to determine whether it discloses sufficient evidence -- that is, evidence that is reasonable, credible, and of solid value -- supporting the decision, and not whether the evidence proves guilt beyond a reasonable doubt.” (People v. Jennings (2010) 50 Cal.4th 616, 638 .) “Section 236 defines misdemeanor false imprisonment as ‘the unlawful violation of the personal liberty of another.’ It is punishable as a felony if ‘effected by violence, menace, fraud, or deceit.’ (§ 237, subd. (a).) . . . [¶] . . .[¶] “ ‘Violence’

2022“Section 236 defines misdemeanor false imprisonment as ‘the unlawful violation of the personal liberty of another.’ It is punishable as a felony if ‘effected by violence, menace, fraud, or deceit.’ (§ 237, subd. (a).) Force is an element of both misdemeanor and felony false imprisonment, but to elevate the crime to a felony, the force used must be ‘greater than that reasonably necessary to effect the restraint.’ [Citation.]” (People v. Newman (2015) 238 Cal.App.4th 103, 108 (Newman).) “ ‘Violence’ in the statute means the exercise of physical force ‘greater than that reasonably necessary to ef

2025As set forth above, this exception applies “ ‘when . . . the statute contemplates a continuous course of conduct or a series of acts over a period of time.’ ” (People v. Jennings, supra, 50 Cal.4th at p. 679 .) “ ‘False imprisonment is the unlawful violation of the personal liberty of another.’ (§ 236.) The offense rises to the level of a felony when ‘effected by violence, menace, fraud, or deceit.’ (§ 237, subd. (a).)” (People v. Whitmore (2022) 80 Cal.App.5th 116 , 130.) The jury was instructed with respect to count 4 that the People had to prove: “1.

2024We review the entire record in the light most favorable to the judgment below to determine whether it discloses sufficient evidence -- that is, evidence that is reasonable, credible, and of solid value -- supporting the decision, and not whether the evidence proves guilt beyond a reasonable doubt.” (People v. Jennings (2010) 50 Cal.4th 616, 638 .) “Section 236 defines misdemeanor false imprisonment as ‘the unlawful violation of the personal liberty of another.’ It is punishable as a felony if ‘effected by violence, menace, fraud, or deceit.’ (§ 237, subd. (a).) . . . [¶] . . .[¶] “ ‘Violence’

2017In Singleton v. Perry (1955) 45 Cal.2d 489 [ 289 P.2d 794 ], the Supreme Court contrasted malicious prosecution with false imprisonment: “ ‘ ‘“False imprisonment is the unlawful violation of the personal liberty of another” [citation], the interference with the personal liberty of the plaintiff in a way which is absolutely unlawful and without authority.

2017In Singleton v. Perry (1955) 45 Cal.2d 489 [ 289 P.2d 794 ], the Supreme Court contrasted malicious prosecution with false imprisonment: “ ‘ ‘“False imprisonment is the unlawful violation of the personal liberty of another” [citation], the interference with the personal liberty of the plaintiff in a way which is absolutely unlawful and without authority.

2015Section 207, subdivision (a) defines kidnapping as “forcibly, or by any other means of instilling fear, steal[ing] or tak[ing], or hold[ing], detain[ing], or arrest[ing] any person in this state, and carr[ying] the person into another country, state, or county, or into another part of the same county. . . .” “ ‘[T]he forcible detention of a victim is an element of kidnapping and as long as the detention continues, the crime continues.’ ” (People v. Thomas (1994) 26 Cal.App.4th 1328, 1334 .) False imprisonment is “the unlawful violation of the personal liberty of another.” (§ 236.) It is also a

2015Section 207, subdivision (a) defines kidnapping as “forcibly, or by any other means of instilling fear, steal[ing] or tak[ing], or hold[ing], detain[ing], or arrest[ing] any person in this state, and carr[ying] the person into another country, state, or county, or into another part of the same county. . . .” “ ‘[T]he forcible detention of a victim is an element of kidnapping and as long as the detention continues, the crime continues.’ ” (People v. Thomas (1994) 26 Cal.App.4th 1328, 1334 .) False imprisonment is “the unlawful violation of the personal liberty of another.” (§ 236.) It is also a