United States v. Jackson Docket: 19-10070, Opinion Date: February 3, 2022. Jackson violently attacked his girlfriend. The entire attack lasted six-seven minutes. Jackson was convicted of assault resulting in serious bodily injury, 18 U.S.C. 113(a)(6), and kidnapping, section 1201(a)(2). The Ninth Circuit reversed the kidnapping conviction. In kidnapping prosecutions under section 1201(a)(2), courts should consider the factors set forth in precedent to evaluate whether the cha