In State v. Cruz-Pena, the New Jersey Supreme Court held that a jury could make the highly fact-sensitive determination that the defendant committed kidnapping because the victim was held against her will for a “substantial period” where he held her captive for four to five hours while he sexually assaulted her, though he never moved her. In so ruling, the Court gave a useful roadmap of its prior decisions on the subject in Masino, La France, and Jackson.