How have courts interpreted section 288 of section 288, subdivision (b) of the California Penal Code when a defendant directed others to hold down the victim and use a pillow to muffle her screams?

of section 288, subdivision (b): "It was not necessary to accomplishment of the described sexual acts that [the victim] be prevented from moving or from crying out. [Defendant's] described acts therefore exceeded any force necessary to the acts." (Id. at p. 1381.) In People v. Cardenas (1994) 21 Cal.App.4th 927, the court similarly found substantial evidence of force where defendant directed others to hold down the victim and used a pillow to muffle her screams as she was sexually molested. (Id. at p. 940.)