The following excerpt is from People v. Sadler, 2004 NY Slip Op 51020(U) (NY 9/13/2004), 2004 NY Slip Op 51020(U) (N.Y. 2004):
Defendant's actions of grabbing the victim's arm and of pushing her head down towards his penis are sufficient to permit the jury to conclude that the defendant used "forcible compulsion" to compel the victim to perform the sodomy. This is so even though the victim did not immediately cry out or suffer any actual physical injury. See, for example, People v. Smith, 302 AD2d 677, 756 NYS2d 290 (3rd Dept. 2003.)
The case law interpreting "forcible compulsion" holds that "the fact that the complainant did not suffer any physical injury as a result of the sexual attack does not render the verdict against the weight of the evidence." People v. Williams, 259 AD2d 509, 687 NYS2d 167 (2nd Dept. 1999) citing People v. Hodges, 204 AD2d 739, 612 NYS2d 420 (2nd Dept. 1994.) The cases
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