State v. Anderson

Summary

The court held that the evidence was insufficient to establish the asportation element of second-degree kidnapping because moving the victim from inside a house to the more exposed area outside did not increase her isolation or restrict her freedom of movement. It affirmed the menacing conviction, concluding that the defendant’s targeted violence against the victim’s car, combined with his statements, could support a finding that he intentionally placed her in fear of imminent serious physical injury. It also affirmed the ruling on the motion in limine because the trial court permitted inquiry into the victim’s subjective motive but barred argument that she objectively obtained a tactical advantage in the dissolution proceeding.