State v. Cruz-Pena, 243 N.J. 342 (2020)
After attempting to leave a house, a woman was held against her will for approximately 4 to 5 hours and was repeatedly sexually assaulted. The man was subsequently convicted of kidnapping and sexual assault; however, on appeal, the kidnapping conviction was overturned as the confinement was viewed as “incidental” to the sexual assaults. In State v. Cruz-Pena, 243 N.J. 342 (2020) the New Jersey Supreme Court reinstated the conviction for kidnapping.