[JCurwen3]

In most fiction where characters use TK to render an opponent helpless that I've seen, the telekinetic uses their TK to slam them against a wall or something, "pinning" them with high TK strength vertically against that wall; I've seldom seen one hold another person in mid-air to remove their defenses.

Still, I'm kind of agreeing with those that feel being held in mid-air via TK should get the same penalty for bad footing. No footing seems to me to be really bad footing.