California, United States of America
The following excerpt is from People v. J.H. (In re J.H.), H044463 (Cal. App. 2018):
3. We reject minor's contention that victim should have resorted to acts of physical violence, such as hitting or pushing minor, in order to unequivocally communicate to minor that she wanted to stop. Doing so might have prompted a violent physical retaliation. (See People v. Griffin (2004) 33 Cal.4th 1015, 1024-1025 (Griffin) [discussing elimination of resistance requirement from rape statute due to concerns that victims who resisted often suffer greater physical injury].)
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