However, it’s worth noting that in Minnesota, rape committed by someone with whom the victim is in “an ongoing voluntary relationship” was still prosecuted under a different code at the time. This led to some successful deployments of the “voluntary relationship defense,” which entailed a de facto marital rape exception—including in a case of a woman raped by her ex-husband, while their divorce was still pending. He made a video of the rape, filmed while their four-year-old child slept nearby. He was sentenced to just forty-five days in jail, for “invasion of privacy.” Fortunately, this
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