State v. Euton

In State v. Euton, Third Dist. App. No. 2-06-35, 2007 Ohio 6704, the court held that "subtle or psychological force" did not apply in that case because Euton did not have a parent-child relationship with the victim and did not hold a position of authority over him. Appellant had only met the victim two days before the incident occurred and the victim gave no indication in his testimony that he viewed Euton as an authority figure.