In State v. Eskridge (1988), 38 Ohio St.3d 56, 526 N.E.2d 304, a father had abused his four year old child. In order for the life specification to be found, the state was required to show that force had been present in the rape. The Eskridge court concluded that it was. The basis of its determination was that force does not need to be overt and physically brutal, but can be subtle and psychological. Id. at 58-59. It went on to explain that, "the youth and vulnerability of children, coupled with the power inherent in a parent's position of authority creates a unique situation of dominance and control in which explicit threats and displays of force are not necessary to effect the abuser's purpose." It then stated that the perpetrator of the rape was the victim's father and as such, he held a position of authority over her which did not require any explicit threats or display of force. Id. at 59.