Kozlowski

A jury convicted appellants Matthew Mark Kozlowski and Donald Paul Gatson of two counts each of robbery, attempted murder, and kidnapping for purposes of extortion, as well as a single count of carjacking. It found various arming and great bodily injury enhancement allegations to be true and Gatson was found to have suffered two prior convictions. (See Pen. Code, §§ 187, 211, 215, 664, 667, subd. (a); see former §§ 209, subd. (a), 667.5, subd. (b), 12022, subd. (b), 12022.7, subd. (a).) Each was sentenced to four consecutive life terms—two without possibility of parole and two with possibility of parole. Restitution and parole revocation fines were also levied. (See § 1202.45; see former § 1202.4, subd. (b).) On appeal, Kozlowski and Gatson argue that (1) they were unlawfully convicted of kidnapping for extortion because a personal identification number (PIN) code is not property that may be extorted; (2) insufficient evidence supports the verdicts of kidnapping for extortion and attempted murder; (3) the kidnapping for extortion statute is unconstitutionally vague as applied; and (4) the trial court committed various instructional errors. They also challenge their…