Does the Fifth Circuit's interpretation of the term 'abducted' conflict with the ordinary meaning of the term and with the Guidelines' definition's requirement of movement to 'a different location?

QUESTION PRESENTED The meaning of “abducted” as used in United States Sentencing Guideline § 2B3.1(b)(4) and elsewhere throughout the Sentencing Guidelines is the subject of an entrenched circuit split. The Guidelines apply a four-level enhancement if a victim is “abducted” during a robbery and defines “abducted” to mean “that a victim was forced to accompany an offender to a different location.” The Sixth, Seventh, and Eleventh Circuits have held that a victim is not “abducted” if the defendant physically moves the victim from one area of the premises that is the target of the robbery (for example, a bank or store) to another area within that same premises. The Third, Fourth, Fifth, and Tenth Circuits have held, to the contrary, that a victim is “abducted” if the defendant merely physically moves the victim from one room to another room within the same building, or even from one part of a room to another part of that same room. The question presented is: Does the Fifth Circuit’s interpretation of the term “abducted” conflict with the ordinary meaning of the term and with the Guidelines’ definition’s requirement of movement to “a different location”? ii