State v. Boyd, 214 N.C. App. 294 (Aug. 2, 2011)

In a kidnapping case, the trial court erred by submitting the theory of removal to the jury. Although evidence supported confinement and restraint, no evidence suggested that the defendant removed the victim in a case where the crime occurred entirely in the victim’s living room. The court stated: “where the victim was moved a short distance of several feet, and was not transported from one room to another, the victim was not ‘removed’ within the meaning of our kidnapping statute.”