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Circuit courts are currently split on how to apply the robbery abduction enhancement contained in the United States Sentencing Guidelines. As a result of patchwork interpretations and a failure to agree on when an abduction occurs, courts have come to drastically different conclusions in almost identical cases. In order to resolve the circuit split, courts need a functional test that applies a unified definition of location.

This Comment seeks to provide courts with such a test. In proposing this test, this Comment looks to (1) the Guidelines, (2) sexual assault case law, and (3) kidnapping case law

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