Delgado-Hernandez v. Holder, 581 F.3d 1059 (9th Cir. Sept. 9, 2009) (California conviction of kidnapping, in violation of California Penal Code 207(a), constitutes a crime of violence under 18 U.S.C. 16(b), and is thus an aggravated felony under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F); kidnapping inherently involves a direct confrontation with a victim who is forced or frightened into being moved involuntarily, which creates a substantial risk of the use of force).

NOTE: This decision seems to ignore a form of kidnapping, explicit in the statute, that would not involve a risk of force: "For purposes of those types of kidnapping requiring force, the amount of force required to kidnap a resisting infant or child is the amount of physical force required to take and carry the child away a substantial distance for an illegal purpose or intent." California Penal Code 207(e).