Curtis v. State, 310 Ga. App. 782

Curtis was convicted after a jury trial of aggravated assault with intent to murder, kidnapping with bodily injury, aggravated battery, and hindering a 9-1-1 call.
Victim was Curtis's girlfriend; she was assaulted in March 2008 after staying home from work due to illness.
Curtis dragged and attacked the victim inside the home, using a variety of weapons and inflicting serious injuries.
Curtis threatened the victim and attempted to prevent her report to authorities, including breaking phones and staging a break-in lie.
Evidence of asportation and the nature of the offenses were central to the kidnapping conviction, which Curtis challenges on appeal.
The trial court denied Curtis's request to charge false imprisonment as a lesser-included offense of kidnapping, which the appellate court later reverses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence supports kidnapping with bodily injury	Curtis contends no sufficient asportation evidence	State asserts Garza standard satisfied	Kidnapping evidence sufficient under Garza
Whether the trial court erred by not charging false imprisonment as a lesser offense	Curtis claims false imprisonment could be proved	State argues no lesser-included charge required	Error in failing to charge false imprisonment; kidnapping conviction reversed

Garza v. State, 284 Ga. 696 (2008) (establishes four-part Garza test for asportation)
Lyons v. State, 282 Ga. 588 (2007) (pre-Garza standard on asportation sufficiency)
Edwards v. State, 264 Ga. 131 (1994) (requires charging lesser offenses where evidence supports them)
Hall v. State, 308 Ga. App. 858 (2011) (examples of Garza-related asportation analysis)
Henderson v. State, 285 Ga. 240 (2009) (illustrates Garza-related asportation considerations)