United States v. Ventura, 565 F.3d 870 (D.C. Cir. May 15, 2009) (generic definition of "kidnapping," under Guidelines, requires "(1) an act of restraining, removing, or confining another; and (2) an unlawful means of accomplishing that act [i.e., by force] . . . . The most common approach defines kidnapping to include [in addition] a particular nefarious purpose. And the majority approach requires some kind of heightened intent beyond the mere intent to restrain the victim's liberty. Most critically, a substantial majority of jurisdictions-forty-four out of fifty-two-require some additional element of intent or severity.").