People v. Quintana

In People v. Quintana (2001) 89 Cal.App.4th 1362, the court applied the Karsai rape penetration standard to the offense of "foreign object penetration" and equated the two penetrations. (Quintana, supra, 89 Cal.App.4th at pp. 1364, 1366.) The court explained that the external female genitalia includes, among other things, the exterior vaginal lips (labia majora) and the clitoris. (Id. at p. 1371.) The court reasoned, therefore, that any contact inside the exterior vaginal lips, including with the clitoris, constitutes the penetration required for object penetration and for rape, vaginal penetration is unnecessary. (Id. at pp. 1366, 1371.)