Esquivel-Castillo v. People

Summary

The court held that the felony-murder count was not limited by the separate, more specific kidnapping count because the felony-murder count did not incorporate that count by clear and specific reference. Accordingly, jury instructions allowing conviction based on any statutory form of kidnapping supported by the evidence did not constructively amend the information or deprive the defendant of adequate notice. The court affirmed the court of appeals' judgment.