Vanderbilt Law Review

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In reviewing Cowan v.State, the Tennessee Supreme Court noted the following facts: Defendant, seeing an automobile stop at an isolated spot on a so-called "lovers' lane," approached it by way of a woods, being unseen by the two teen-age couples in the automobile until he was quite nearby. The occupants' attempt to drive away was thwarted by the defendant's exhibiting and threatening to use a pistol, warning against further escape attempts, and demanding and receiving the ignition key. He then insisted that the girls have sexual intercourse with him; and when they refused, he stated that he would not "take it" but would keep them there until they "give it"to him. Subsequently, against resistance, he made attempts at fondling the girls until some seven hours later, at 3:30 A.M., he returned the ignition key and permitted the four young people to leave.

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