In a case decided earlier this month, the Court of Appeals overturned the defendant’s conviction for kidnapping when the evidence showed only an unsuccessful carjacking. See State v. Andrews, No. COA23-675 (N.C. Ct. App. July 2, 2024). Given the particular facts of the case – the defendant threatened the victim with a firearm, the victim fled in his car, and the defendant gave chase in his van – the Court of Appeals might have concluded that a car chase does not constitute the sort of confinement, restraint, or removal that G.S. 14-39 (kidnapping) was intended to address. Instead, it held that the defendant’s high-speed pursuit of the victim was a restraint that was not sufficiently distinct from that inherent in the attempted armed robbery. Citing double jeopardy concerns, the Court of Appeals reversed the kidnapping conviction. This post examines the opinion in Andrews.