United
States v. Contreras, 69 M.J. 120 (kidnapping is
not a purely
military offense, where the MCM does not limit the application of that
offense
to military members only, nor would anyone otherwise consider it to be
a purely
military offense despite the necessity of proving and pleading that the
conduct
was service discrediting or prejudicial to good order and discipline).
United
States v. Thompson, 67 M.J. 106 (after finding
the evidence of kidnapping
factually and legally insufficient because the detention was de
minimis, the
CCA improperly substituted a conviction to reckless endangerment as an
offense
closely related to the offense of kidnapping, where a comparison of the
elements of the two offenses revealed that a conviction for reckless
endangerment required proof of elements that were not included in a
specification for kidnapping, and reckless endangerment was not an
offense
necessarily included in the offense of kidnapping).