Ward v. State, 324 Ga. App. 230

Ward, married to the victim in 1999, had a history of domestic violence and stalking; they divorced in 2007 but he continued to pursue her between 2008–2010.
In early 2010 Ward forced the victim to have sex in his car after a ride request, threatening to kill her.
On June 8, 2010 Ward lured the victim to a house, grabbed her wrist, and forcibly moved her from the garage into the house, where he raped her.
Ward restrained the victim, prevented her from leaving, and again assaulted her in a bedroom after the initial intercourse; she attempted to call 911 and escape.
The victim reported abrasions; Ward was charged with kidnapping with bodily injury as well as rape and aggravated assault; the jury acquitted on rape and aggravated assault, but convicted kidnapping with bodily injury.
The appellate court held the asportation was not merely incidental, and the indictment was cured for the bodily-injury charge, upholding the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of asportation to convict kidnapping	Ward	Ward	Evidence supported asportation; not merely incidental to other offenses.
Jury charge on kidnapping with bodily injury	Indictment allowed rape-based bodily injury; charge mis-stated.	Charge permitted any injury; need for limiting instruction.	Court cured by reading indictment and instructing burden beyond reasonable doubt; no reversible error.

Brashier v. State, 299 Ga. App. 107 (2009) (establishes requirement of unlawful movement for asportation)
Williams v. Kelley, 291 Ga. 285 (2012) (indictment reading cures jury-charge defect when burden explained)
Garza v. State, 284 Ga. 696 (2008) (four-part Garza test for asportation sufficiency)
Hammond v. State, 289 Ga. 142 (2011) (amendment allowing slight movement unless incidental to another offense)
Taylor v. State, 282 Ga. 502 (2007) (abolished inconsistent verdict rule; multiple theories allowed)