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F 9.51 n1 Appellate Issue Alert: Pre-1997 Version.
The pre-1997 version of CJ 9.51 failed to define “lewd or lascivious act.” (See CALJIC History CJ 9.51.)
F 9.51 n2 Aggravated Kidnapping: Substantially Increased Risk Of Psychological Harm Is Sufficient.
People v. Nguyen (2000) 22 C4th 872, 886 [95 CR2d 178] held that psychological harm may be enough to support a conviction for aggravated kidnapping (PC 209(b)).