People v. Warren
Illinois Appellate Court
113 Ill. App. 3d 1 (1983)
Relevant factsFree
Warren (defendant), a much larger man, approached a woman on a trail, walked with her to her bicycle, then told her "this will only take a minute" and that he didn't want to hurt her before carrying her into a wooded area, where she undressed at his direction and ultimately performed fellatio on him without further physical force, threats, or a weapon being used. Convicted of deviate sexual assault after a bench trial, Warren appealed, arguing the prosecution failed to prove he used force or threat to compel the act.
IssueFree
Whether a conviction for deviate sexual assault requires proof that the defendant used force or threat to compel another to perform or submit to the act.