Can you trap flyers?

You would think they would just fly up and away...

We thought about Fellbeast, and proposed you possibly could trap it against a building or edge of woods.

We thought about Bat Swarms, and it seemed to us, these would just disperse to reform later, as swarms do in nature... you couldn't really trap them.

Discussion welcome

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There are no rules exceptions for flyers, so they stay trapped, you could argue that there is insufficient room to get the wings a-flapping.