(Jamie O’Leary ’19 wrote this as a final paper for GSS 305: Feminist Approaches to Bioethics, with Prof. Catherine Clune-Taylor.)

Female contraception has long been celebrated for giving women reproductive choice. Oral contraceptives were a hard-won battle for feminists in the 1960s; the Pill meant that women could make individual reproductive choices, break away from traditional gender roles, and have more control over their bodies and sex lives (Vogels, 16). The IUD was an additional victory, giving women a contraceptive choice which requires no daily effort and offers flexibility. However, female contraception[1] is a complex technology; it is highly effective and provides women with peace of mind and the ability to have non-procreative heterosexual sex, but the perceived empowerment, control, and choice it affords women are paradoxical, situated, and often illusory. For sexually active heterosexual women, the embodiment of female contraception is practically mandatory. Women may choose between a limited set of options, but what they cannot choose is that their bodies will be altered in often-painful ways and reconstructed and regulated in accordance with sexist norms and capitalist ideals, while their male partners’ bodies remain untouched. Thus, an examination of women’s embodiment of female contraception complicates the idealized reproductive “choice” concept, revealing female contraception to characterized by constraint, inequality, and forced embodiment.

Long-term female contraceptives mandate that women embody technology, leading to the fusion and mutual reconstruction of technologies and bodies. Donna Haraway argues that all humans are cyborgs, or “couplings between organism and machine” (150). Our bodies are remade by technologies, and the social and the technological interact with our physical bodies to shape our subjectivities. In turn, bodies shape technologies; Anni Dugdale argues that “the ontology of the IUD, and the ontology of women’s bodies, what each is, are intricately linked together” (184). Reproductive technologies thus reconstruct and become a part of women’s bodies in significant ways, just as technologies are shaped by the bodies they are designed for.

Women’s bodies are reimagined and remade by pharmaceutical companies that design technologies for a standardized body and an “ideal user.” Dugdale argues that IUDs were first designed for two different groups of users. The first was the “sex-reform IUD” born in the 1920s. In response to budding discourses of equal rights to sexual pleasure, Dr. Ernst Gräfenburg advertised a technology that could create the body of a new, “liberated” woman; “this was the desiring body, subject to various tastes, part of a scientific world that promised a rational and equitable society” (169). In contrast, the “population-control-IUD” was designed for large-scale population control in masses of “unmotivated” women – poor women of color and women in the Global South – deemed incapable of controlling their reproduction. In both cases, a standardized technology was designed to fit and shape a standardized body. Similarly, Chikako Takeshita points out that after the disastrous recall of the Dalkon Shield IUD in the 1970s, pharmaceutical companies reimagined the ideal IUD user. In order to present other IUDs as safe, they claimed that the Dalkon Shield’s danger was the fault of women with STIs. Thus, they marketed IUDs to “a population that appeared to be the safest both socially and medically;” mothers with no STI history, who were assumed to be non-promiscuous and less likely to press charges if they became infertile (Takeshita, 46). “A safe technology, then, was co-produced with a safe body through scientific invention and social imagination” (Takeshita 47).  Thus, bodies and technologies are reconstructed to fit visions of a standardized and ideal user with profit in mind.

Female contraception is designed for and fabricates standardized bodies, but women’s embodied experiences of it are anything but standardized. In practice, contraception interacts with individual women with unique bodies, identities, and life-worlds. Thus, to understand how women’s bodies and subjectivities are reconstructed by reproductive technologies, we must consider the embodied experiences of individual women. In order to do this, I interviewed thirteen undergraduate women at Princeton University about their embodied experiences with the Pill and with hormonal and copper IUDs.[2] Although these women come from relatively diverse socioeconomic backgrounds, none of them have had their access to contraception restricted and none have been explicitly coerced to use it.[3] Thus, this group of women is not representative of all women; instead, they provide insight into 13 individual embodied experiences. These interviews illuminate patterns in how women in positions of privilege experience, understand, and negotiate the way female contraception reconstructs their bodies, while also suggesting that women’s embodied experiences of female contraception are unique, diverse, and situated.

A central part of female contraception embodiment is side effects; each method has side effects that vary greatly in nature, frequency, and intensity in different women’s bodies. According to a 2013 CDC report, 88% of women surveyed who had ever had sexual intercourse had used a form of long-term female contraception, and 82% had used the Pill (Daniels, Mosher and Jones). Out of those Pill users, 30% discontinued because of dissatisfaction; 62% of discontinuations were due to side effects and another 12% were due to concerns about side effects. Side effects for oral contraceptives can include nausea, dizziness, headaches, changes in mood, weight gain, breast tenderness, and irregular bleeding (“In-Depth Report”). Phoebe[4] recounted that when she was taking the Pill, “I got very bloated in my stomach, and I was already struggling with some depression… it made everything worse and I started having suicidal thoughts… just feeling heavy and sad so often.” When she switched pills, “it just was so awful… nothing changed, if anything I just got even more bloated so I stopped taking them.” Nicole said that on the first couple of pill brands she tried, “I’d just feel like really nauseous in the morning. I’d never throw up but it was just not pleasant.” Out of 13 interviewees, 12 had used the Pill at some point, and all 12 experienced changes in their bodies. Nine had side effects they described as painful or worrying, and the remaining three stated that their side effects – including acne reduction and lighter periods – were solely positive. IUDs come with a different set of side effects which also vary between women, including ovarian cysts, pelvic pain, headaches, mood changes, and acne (Beck). Hormonal IUDs often cause highly irregular periods or stop menstruation altogether, whereas copper IUDs often cause heavier bleeding and increased cramping. A central part of IUD embodiment is the often-painful insertion of the IUD into the uterus through the cervix, which can cause cramping and bleeding and poses a small risk of uterus perforation (“Safety Considerations”). Mary recounted, “oh, it was horrific…they had to force your cervix open and since I didn’t have any numbing… I was on the floor, like I made it back to my room and I just collapsed, just horrible cramps… [my boyfriend] picked me up and put me on my bed.” Despite being able to choose a contraceptive method based on a list of possible side effects, a woman cannot know how a method will interact with her body until she embodies it. Many interviewees suggested that women need to keep trying different female contraceptive methods until they find one that does not cause unacceptable side effects in their body. In other words, for many, painful side effects seem to be an inevitable step in the process.

Although many women use female contraception to have safer, more comfortable sex[5], it can interfere with women’s sex lives. Side effects such as decreased libido, irregular or heavy bleeding, and weight gain can make women feel unsexy and inhibit them from having the sex that motivated them to use contraception in the first place. Kiki’s Pill use took a toll on her sex life: “I had a really really heavy period… it’s really messy when you want to have sex and it’s like not fun and I felt really uncomfortable… I felt self-conscious in my relationship as well, having put on weight… I wouldn’t feel comfortable being naked a lot.” Ironically, the Pill that Kiki started to improve her sex life sabotaged it. Societal expectations for women’s bodies and menstrual taboo also likely factored into her negative experience of birth control embodiment.

Birth control alters not just women’s physical bodies but their perceptions and inhabitation of them as they move through the world. In her study of Pill users, Sharon Vogels found that “the pill had implications for how women understood and experienced their physical bodies” (77). She argues, “the pill was an agent of transformation… this construction frequently impaired, rather than benefited, [women’s] physical and emotional well-being” (79). In the interviews I conducted, the results were similar. Some women felt that their contraceptive use did not alter their perception or experience of their bodies, but others felt experienced profound and often negative changes. Kiki explained that even though she has stopped using the Pill, “I don’t feel comfortable in my own body and now I’m still in the process of losing the weight that I’ve gained… that’s just a tragedy for me because I love cooking and I love food.” Kiki’s Pill-induced weight gain changed her perception of and feelings about her body even after she stopped taking it, and it keeps her from enjoying food, once a central part of her life and identity. Emily described her weight gain after beginning the Pill similarly, saying that she has developed “body self-hatred.” Emma, Phoebe, and Shelby all experienced new or worsened depression after going on the Pill; birth control altered not just their physical bodies but their emotions and mental state, and therefore their experience of daily life. Emma reported, “I’d come home from school and then just lie in bed crying all afternoon.” Female contraceptives do not simply change women’s physical bodies, but they also alter women’s understandings and experiences of them.

As reproductive technologies reconstruct their bodies, women often express frustration at not knowing which of their ailments are caused by their contraception and which are just them. Emily wondered, “My mood swings, what is that about? Is that about the hormones or just like my moods?” Carmen stopped her Pill use because she felt intense anxiety; she was not sure whether it was the Pill itself or her fears about Pill side effects that caused it. These interviewees and most others struggled to distinguish between what is them and what is their birth control. Haraway would argue that there is no distinction; when women take female contraception, it becomes a part of them, reconstructing and joining with their very bodies.

It could be argued that the unpredictable and often-miserable bodily changes caused by female contraception are simply inevitable side effects, like those of any other medication. All medications come with side effects which patients must consider and prepare themselves for before beginning treatment. However, female contraception is not medication, and women who seek it to prevent pregnancy are not sick. Women’s bodies are medicalized and their desire to engage in non-procreative heterosexual sex is treated as an illness for which they are expected to accept often-agonizing side effects and significant bodily reconstruction. Women are not the only ones who desire non-procreative heterosexual sex, yet the desires of heterosexual men and women are reflected onto the bodies of women alone. Highly effective long-acting contraception for men has been developed, yet pharmaceutical companies are hesitant to invest in it (Altstedter). Furthermore, a recent trial of a male contraceptive shot was halted because men experienced side effects: the same ones that women suffer from when using female contraceptives that are already FDA approved (Beck). Widespread attitudes that women should bear the burden of contraception persist, and this inequality is reinforced by the narrative that sexually active heterosexual women who do not use female contraception are irresponsible. According to Granzow (2008), “A woman is not responsible first and therefore chooses to use contraception. Rather, in using contraception she demonstrates her responsibility… being responsible via pill use might be a well-internalized imperative. Again, ‘choice’ as a one-dimensional concept drops away” (13). This “well-internalized imperative” leads to the exclusive and practically mandatory embodiment of contraception by sexually active heterosexual women, which challenges the concept of “reproductive choice.” Women can choose what contraceptive method to use, but they have little choice in whether they will use one. Thus, women can choose which set of side effects they will potentially experience – it is impossible to know how their individual bodies will respond – but what they cannot choose is that their bodies (and not their male partners’) will be altered and reconstructed in significant and often painful ways.

Although many interviewees reported that male sexual partners were willing to use condoms as an added contraceptive measure and for STI prevention, others reported that their female contraceptive use led partners to protest using a condom. Priscilla explained, “When I told guys I was on the Pill they would try harder to get me to not use a condom…I guess that’s like part of the reason I wanted to go off the Pill… I should just lie and tell them I’m not on the Pill but that’s not my instinctive reaction.” Priscilla’s use of the Pill made negotiating safer sex more difficult, this factored into her decision to stop using it altogether. Similarly, Mary said, “What actually happens is unless I ask, people try to avoid [wearing condoms]… I’ll have to bring it up and they’ll say, ‘Oh no, I don’t do that. I don’t have sex with condoms.’ You can say that, but you’re not going to have sex with me… most will cave and it’s like totally fine after that. Some don’t and I’m like, ‘bye,’ and that’s the end of it.” This unwillingness to use condoms highlights the attitude that women alone should be responsible for contraception. Four interviewees reported that they did not use condoms to supplement their female contraception, saying that condoms made sex less pleasurable for their male partners. This is a trope that dominates discourse around condoms in the United States, yet a 2013 study found that “participants consistently rated sex to be arousing and pleasurable whether or not they used condoms or lubricant. No significant differences were found in regard to men’s ratings of the ease of their erections based on condom and lubricant use” (Herbenick et al., 474). It is likely that pornographic norms, feelings of entitlement, and popular discourse factor into this “reduced pleasure.” Even if condoms do reduce physical sensation, it is significant that men’s slightly reduced pleasure is seen as unacceptable by many heterosexual men and women, whereas women’s pain and bodily transformation caused by female contraception is normalized.  Although the expectation that women will be responsible for and embody contraception is unjust, female contraception also gives many women feelings of control over their bodies and empowerment to use them in the ways they wish. However, notions of control and empowerment are situated and often paradoxical. Phoebe recounted, “With my [copper] IUD, I definitely walked out feeling very empowered and excited because it was the most low-activity form of maintaining sexual freedom.” The copper IUD, with its invasive insertion process and increased menstrual bleeding and pain, is hardly “low-activity.” However, Phoebe perceived it as the most low-activity of the few, high-activity contraception options that sexually active heterosexual women must choose between. Thus, this empowerment exists in the context of extremely limited options. Furthermore, various interviewees pointed out that their bodies that will have to carry any unintended fetuses, and they cited this as a reason for their desire to have control over contraception. With female contraception, they felt empowered to have sex without fear of pregnancy. The burden of unintended pregnancy on women extends far beyond the physical; there is a societal imperative for women to be the primary caretakers of children, especially unintended ones. Furthermore, women are shamed and blamed for unintended pregnancy; the “teen mom” has become fear-inducing cultural icon, and abortion is similarly frowned upon. Unintended pregnancy does not just affect women physically, but it disproportionately derails their lives and damages their reputations. Women’s feelings of empowerment through birth control are thus situated in a social context that makes sex especially high-risk for them.

Desires for control over one’s body and reproduction can also stem from the stripping of women’s reproductive and sexual control. For example, Kiki explained that in her last relationship, she refused to have sex without a condom despite her boyfriend’s protests. One day, her boyfriend removed the condom during sex without her knowledge or consent. “I was really, really hurt… that was like a reason why I decided to go on birth control, because I felt like I couldn’t trust a condom. I felt so helpless in that moment… I didn’t feel like I was in control.” Kiki began using the Pill because her consent – and thus her sense of control – was violated. Such violations of women’s control over their bodies are frequent and systemic. Female contraception helps women regain control over their bodies, but it also cedes control to contraceptive manufacturers that alter and reconstruct them. Granzow (2007) writes, “The need to control one’s body, and specifically to control women’s processes of reproduction, is apparently not only a matter of choice but also one of constraint” (48). The control female contraceptive users feel is legitimate, but also partial and situated within conditions of constraint.

Menstrual regulation and suppression are examples of the paradoxical and illusory nature of women’s control through female contraception. The traditional Pill is a cycle of three weeks of hormonal pills and a week of sugar pills, during which women bleed. This initially seems to be a way of maintaining “natural” menstruation while also making it more predictable, controlled, and convenient. Alexandra said, “It’s insane, I love it. I know almost the time of day when I’m gonna get it, so I can prepare for that. My flow is less, and lasts fewer days.” Users can even skip their week of sugar pills in order to skip their periods altogether, and interviewees report having done this for romantic encounters or trips to the beach. Many women perceive this control over menstruation – a bodily function which is typically uncontrollable and inconvenient in a society where it is taboo– as liberating. However, many women also believe it is important to have a period, and express discomfort at the idea of suppressing their periods altogether. Alexandra said, “They’re like enough of a sign to me that I’m not pregnant that it makes me feel much more calm and less anxious.” Priscilla said that not having a natural period “just seems like a biologically weird thing.” These comments from women on the traditional Pill, who express desires for natural menstruation and reassurance they are not pregnant, reveal a fundamental misunderstanding of how the Pill works. According to Takeshita, “believing that women wished to feel that they were menstruating normally and in order to create a marketable drug, pill developers built the 7-days-every-21-days bleeding period into the product… a ‘normal’ woman with a regular four-week menstrual cycle was configured and produced by technoscience” (50). Women’s monthly bleeding on the traditional Pill is simply a reaction to hormone withdrawal from the sugar pills; there is no ovulation and no “naturalness” whatsoever. The “control” over one’s period is not control at all, because there is no period. It is an illusion created by pharmaceutical companies to sell products, and women are shockingly unaware of it. Six of my interviewees expressed disbelief when they learned this. Phoebe exclaimed, “that’s so fucked up!” Alexandra responded, “I’m a victim of capitalism… so what’s happening to my eggs then?” Traditional oral contraceptive users’ bodies are reconstructed – often without their knowledge – to become paradoxically clean and convenient yet “feminine” and “natural.”

Many female contraceptives offer women the chance to limit or fully suppress menstruation, but this takes advantage of menstrual shame, offers a false sense of control, and reconstructs the women’s bodies to fit sexist norms and the demands of a capitalist society. Advertising for hormonal IUDs and menstruation-suppressing oral contraceptives such as Seasonale and Lybrel features care-free, modern, “liberated” women, implicitly critiquing menstruation and painting contraception as a lifestyle drug that can fix it. Takeshita writes, “By casting menstruation as messy, inconvenient, and undesirable, menstrual suppression offered a seemingly natural solution to a distinctly gendered problem” (51). Thus, pharmaceutical companies play up pervasive and sexist menstrual taboos for profit. Furthermore, menstruation-suppressing contraceptives do not work perfectly, leaving many women with cramps and bleeding that they were promised they would be rid of. In addition, menstrual suppression reconstructs women’s bodies in significant ways. Takeshita argues that menstrual suppression produces “flexible bodies well-adapted to neoliberal capitalism. These bodies are productive and well-managed, clean and healthy, not overly reproductive, good consumers of high tech products, and above all flexible” (51-2). Although this flexibility can be enjoyed by women, it also shapes their bodies to fit capitalist demands. Repta and Clarke argue that women’s natural bodies are cast as deviant, and that “controlling one’s menstrual cycle… produces a self-disciplined body that more closely resembles a male body” (104). Additionally, in their analysis of Seasonale marketing, Mamo and Fosket write, “we are to conclude that menstruation is to be avoided so that women can be rendered ready and clean for sexual penetration” (938). Through menstrual suppression, women’s bodies are readied for male use and altered to become more similar to those of men. Therefore, in choosing the control of menstrual suppression (certainly convenient in a society that teaches women to hide and despise menstruation) women must also relinquish their bodies for regulation by companies and reconstruction in accordance with sexist ideals. The flexibility and control women attain, then, are limited and paradoxical.

If a woman does not want her period suppressed, her only option is the copper IUD, which instead intensifies the period. Thus, female contraceptive users have no choice but to have their menstruation altered, which in turn alters how they experience and understand their bodies in both positive and unsettling ways. It is important to note that for some, including interviewees Emma and Mary, menstruation-suppressing birth control alleviates excruciating cramps and extreme bleeding that they describe as “crippling” and “horrific.” These women use birth control as medication, not just contraception. Many women, even those who do not have debilitating periods, use menstrual suppression to treat pain. However, it must be acknowledged that menstrual suppression is not simply for pain reduction but for the reconstruction of women’s bodies in response to menstrual stigma and in line with capitalist ideals and corporate profitability. In the words of Mamo and Fosket, “synthetic chemicals not only alter bodies and their menstrual flows; these bodily changes are also given social and cultural meaning” (932).

Women’s choices and control over their bodies are limited through female contraception, but women negotiate their own agency within this constraint. When Shelby first started on the Pill it made her depressed, and a second Pill made her “sick all the time.” She also had trouble fitting the Pill into her schedule, and her inconsistent use made her anxious. After realizing the Pill was not an option for her, Shelby got a hormonal IUD. When it was inserted, she said, “I got really really sick… I like threw up and passed out and had to go to the hospital… Everybody’s automatic reaction was ‘Take the damn thing out!’” However, Shelby refused to have her IUD taken out, insisting on giving it more time because she felt like she had no other contraceptive choices. She said, “I don’t know if there’s anything else that’s similarly high-effective as like the IUD… which is why I think I was so determined to make the IUD work.” Like Shelby, each woman has a unique and constricted set of female contraceptive options based on her body, her financial situation, and her life-world. Shelby’s story of navigating those options is one of both agency and constraint. She stopped taking Pills that negatively impacted her body and her life, and in keeping her IUD she advocated for herself and her ability to have safe, worry-free sex. However, extremely limited options influenced her decision to “keep the damn thing in” despite the likelihood that the IUD triggered her hospital visit. Women like Shelby are agents who make reproductive choices, but must they negotiate within a context of constraint.

In conclusion, the discourse of “choice” that surrounds female contraception must be challenged. Sexually active heterosexual women have little choice but to “choose” between limited and invasive forms female contraception. They have no choice in that they will likely embody their contraception in unpredictable and painful ways that will alter their menstruation, sex lives, daily lives, and perceptions and experiences of their bodies. They must surrender their bodies to medicalization and reconstruction by technology in alignment with visions of a standardized user, corporate schemes, and sexist norms. Thus, the notions of choice, control, and empowerment often associated with female contraception are in fact situated, paradoxical, and deceptive, requiring women to negotiate within a context of constraint. Why must women who want to have heterosexual sex pay such a high price for an act shared with men whose bodies are left untouched? New choices must be made; choices to research and invest in better technologies, choices on the part of men to take some of the burden off, and choices to stop uncritically praising female contraception and start demanding choice in a fuller form.

Work Cited

 Alexandra. Personal interview. 6 May 2017.

Altstedter, Ari. “New male contraceptive is safe, effective and inexpensive – but no company has agreed to sell it.” Chicagotribune.com. N.p., 01 Apr. 2017. Web. 16 May 2017.

Amanda. Personal interview. 8 May 2017.

Beck, Julie. “The Different Stakes of Male and Female Birth Control.” The Atlantic. Atlantic Media Company, 01 Nov. 2016. Web. 13 May 2017.

“Birth Control In-Depth Report.” The New York Times. The New York Times, n.d. Web. 14 May 2017.

Carmen. Personal interview. 9 May 2017.

Daniels, Kimberly, Ph.D, William Mosher, Ph.D, and Jo Jones, Ph.D. Contraceptive Methods

Women Have Ever Used: United States, 1982–2010. Rep. no. 62. N.p.: U.S. Department of Health and Human Services, 2013. Print.

Dugdale, Anni. “Intrauterine Contraceptive Devices, Situated Knowledges, and the Making of Women’s Bodies.” Australian Feminist Studies 15.32 (2000): 165-176.

Emily. Personal interview. 4 May 2017.

Emma. Personal interview. 6 May 2017.

Granzow, Kara. “De‐Constructing ‘Choice’: The Social Imperative and Women’s Use of the Birth Control Pill.” Culture, health & sexuality 9.1 (2007): 43-54.

Granzow, Kara. “The Imperative to Choose: A Qualitative Study of Women’s Decision-Making and Use of the Birth Control Pill.” Social Theory & Health 6.1 (2008): 1-17.

Haraway, Donna. “A Cyborg Manifesto: Science, Technology, and Socialist-Feminism in the Late Twentieth Century.” Simians, Cyborgs, and Women: The Reinvention of Nature.  Florence: Taylor and Francis, 1990. 149-81. Print.

Herbenick, Debby, et al. “Characteristics of Condom and Lubricant Use Among a Nationally Representative Probability Sample of Adults Ages 18–59 in the United States.” The journal of sexual medicine 10.2 (2013): 474-483.

Kiki. Personal interview. 6 May 2017.

Mamo, Laura, and Jennifer Ruth Fosket. “Scripting the Body: Pharmaceuticals and the        (Re)Making of Menstruation.” Signs: Journal of Women in Culture and Society 34.4     (2009): 925-949.

Mary. Personal interview. 11 May 2017.

Nicole. Personal interview. 9 May 2017.

Phoebe. Personal interview. 10 May 2017.

Priscilla. Personal interview. 6 May 2017.

Repta, Robin, and Laura Hurd Clarke. ““Am I Going to be Natural or am I Not?”: Canadian Women’s Perceptions and Experiences of Menstrual Suppression.” Sex roles 68.1-2      (2013): 91-106.

“Safety Considerations.” Safety Considerations | Mirena® IUD. N.p., n.d. Web. 14 May 2017.

Sharon. Personal interview. 5 May 2017.

Shelby. Personal interview. 6 May 2017.

Sydney. Personal interview. 6 May 2017.

Takeshita, Chikako. “The IUD in Me: On Embodying Feminist Technoscience Studies.” Science    as Culture 19.1 (2010): 37-60.

Vogels, Shannon. The Birth Control Pill: Popular Discourse and Personal Experience. Thesis. University of Calgary, 2009. N.p.: Simon Fraser U, 2013. Print.

 

I pledge my honor that this is my own work in accordance with University regulations.

X Jamie O’Leary

[1] I have chosen to focus on the Pill and the IUD in this paper because these are the methods considered and used by the women at Princeton University who were interviewed for this research. However, the themes addressed in this paper are applicable to any long-term female contraceptive method, including implants and injections.

[2] These interviewees were primarily friends and acquaintances with whom I had never previously discussed contraception, and a few were recruited through snowball sampling.

[3] Although it is outside the scope of this paper, it is imperative to consider that the reproductive choice of poor women of color and women in the Global South is often severely restricted through coercive policies, forced sterilization, and nonconsensual contraceptive vaccination or implantation. This bodily reconstruction is undergone even less voluntarily than that of the women discussed in this paper. See Dorothy Roberts.

[4] All names have been changed for privacy.

[5] For the purpose of this paper, “sex” shall refer to vaginal penetration by a penis. However, “sex” can generally refer to a variety of other activities.

Advertisements