• Connecticut Appellate Court
  • Sheldon, J.
The Connecticut Supreme Court recently determined that when a defendant engages in conduct that would otherwise constitute the crime of kidnapping in the first degree while committing another substantive criminal offense, Connecticut General Statutes §53a-92(a) requires proof of an additional element, specifically, that the defendant intended, as stated in the Court's 2008 decision in State v. Salamon, "to prevent the victim's liberation for a longer period of time or to a greater degree than that which is necessary to commit the other crime."