United States v. Gonzales-Ramirez, 477 F.3d 310 (5th Cir. Jan. 30, 2007) (Tennessee conviction for kidnapping, in violation of Tenn. Code Ann. 39-13-303 ["false
imprisonment . . . (1) [u]nder circumstances exposing the other person to substantial risk of bodily injury; or (2) [w]here the confinement of another is in a condition of involuntary servitude] meets generic definition of "kidnapping," [adopting model penal code definition] for purposes of the "crime of violence" definition used in enhancing a sentence upon illegal re-entry prosecution).
http://caselaw.lp.findlaw.com/data2/circs/5th/0451355cr0p.pdf



NOTE: Model Penal Code 212.1 defines kidnapping as:



unlawfully remov[ing] another from his place of residence or business, or a substantial distance from the vicinity where he is found, or . . . unlawfully confin[ing] another for a substantial period in a place of isolation, with any of the following purposes:
(a) to hold for ransom or reward, or as a shield or hostage; or
(b) to facilitate commission of any felony or flight thereafter; or
(c) to inflict bodily injury on or to terrorize the victim or another; or
(d) to interfere with the performance of any governmental or political function.
. . . A removal or confinement is unlawful within the meaning of this Section if it is accomplished by force, threat or deception, or, in the case of a person who is under the age of 14 or incompetent, if it is accomplished without the consent of a parent, guardian or other person responsible for general supervision of his welfare.