A major consideration in the reform of rape laws across the country has been the use of force. Recent court decisions, one in Pennsylvania and one in California, have made contradictory rulings concerning the use of force in rape convictions. This article examines some of the legal issues most commonly addressed in any rape case, i.e., consent, resistance, force, and fear. These issues are made more complex by the fact that they are intertwined and interdependent. Background factors affecting the use of force as a necessary element of the crime of rape include a history of the courts' approach to earlier cases of rape and the use of force, and previous rape legislation passed in California. The article also considers how the psychological aspects of rape should, and do, affect the crime of rape and the conviction of rapists. 93 notes