People v. Fields CA2/7

INTRODUCTION

Fitzgerald Fields appeals from the judgment after a jury convicted him of kidnapping and assault. Fields argues that substantial evidence did not support his conviction for kidnapping and that the trial court erred in instructing the jury on kidnapping. We conclude that substantial evidence supported Fields’s conviction, but that the trial court prejudicially erred in failing to instruct the jurors that they could consider whether Fields’s movement of the victim was incidental to his committing assault. Therefore, we reverse.

FACTUAL AND PROCEDURAL BACKGROUND

Fields and his cousin Marilyne Adams lived in a supportive housing complex that served people experiencing homelessness, mental health issues, and substance abuse issues. Fields lived in the complex’s temporary “dorms,” and Adams lived in a permanent apartment. Adams was in her late 60’s, appeared “a bit frail,” suffered from dementia, and had a history of substance abuse. One day in February 2024 a surveillance camera captured a two-minute encounter between Fields and Adams. As Adams walked away from her apartment through a courtyard area, Fields came out of the apartment and walked quickly toward Adams.…