U.S. v. Reynolds

Dist. Ct. erred in sentencing defendant to life imprisonment on kidnapping charge based, in part, on imposition of enhancement under section 2A4.1(b)(1) of USSG where defendant made “ransom demand” during charged offense. New sentencing hearing was required since “ransom demand” for purposes of section 2A4.1(b)(1) requires showing that demand was made to third-party, and record indicated that defendant made said demand only on defendant himself.