United States v. Arreola, 467 F.3d 1153 (9th Cir. Nov. 8, 2006) (18 U.S.C. 924(c)(1)(A), punishing "any person who, during and in relation to any ... drug trafficking crime ... uses or carries a firearm, or who, in furtherance of any such crime, possesses a firearm," describes two alternative means to commit a single offense).

People v. Dalerio, 144 Cal.App.4th 775 (Nov. 7, 2006) (California Penal Code 207(e), kidnapping, deceit plus constant physical presence was sufficient to find that defendant had used "force" to kidnap victim, since victim was a minor and was therefore unable to give consent to being taken.).