What is the current state of the law on sexual conduct?

The three-pronged definition of "sexual conduct" offered in Costello in 1977 has persisted in case law. Some courts have adopted it in its entirety (see, People v. Tribble, supra; People v. Fink, N.Y.L.J., May 22, 1992 at 23, col. 4), while other courts have expanded the definition to accommodate new forms of sexual gratification (see, for example,

Page 602