<sod>In 2008, it was reported that a [[Massachusetts]] woman, Marissa Lee-Fuentes, unknowingly had sex with her boyfriend's brother in the dark basement that she was sleeping in. He could not be prosecuted because Massachusetts law then required that rape include the use of force.<ref name="cbs">{{cite news|url=http://www.cbsnews.com/stories/2008/02/29/politics/uwire/main3894875.shtml|title=Rape 'by Deception' May Become A Crime In Massachusetts|date=2008-02-29|work=CBS News|accessdate=24 April 2011}}</ref><ref>{{cite web|url=http://www.npr.org/templates/transcript/transcript.php?storyId=90186100|title=If Your Neighbor Poses as Your Husband, Is it Rape?|publisher=|accessdate=12 July 2016}}</ref> Massachusetts State House Representative Peter Koutoujian crafted rape-by-fraud legislation in response, but it has yet to pass.<eod>
<sod>In 2008, it was reported that a [[Massachusetts]] woman, Marissa Lee-Fuentes, unknowingly had sex with her boyfriend's brother in the dark basement that she was sleeping in. He could not be prosecuted because Massachusetts law then required that rape include the use of force.<ref name="cbs">{{cite news|url=http://www.cbsnews.com/stories/2008/02/29/politics/uwire/main3894875.shtml|title=Rape 'by Deception' May Become A Crime In Massachusetts|date=2008-02-29|work=CBS News|accessdate=24 April 2011}}</ref><ref>{{cite web|url=http://www.npr.org/templates/transcript/transcript.php?storyId=90186100|title=If Your Neighbor Poses as Your Husband, Is it Rape?|publisher=|accessdate=12 July 2016}}</ref> Massachusetts State House Representative [[Peter Koutoujian]] crafted rape-by-fraud legislation in response,<ref>{{cite news|last1=McCartney|first1=Ryan|title=Could a pick-up artist be charged with 'rape by deception'?|url=http://www.nbcnews.com/id/38430181/ns/us_news-crime_and_courts/t/could-pick-up-artist-be-charged-rape-deception/|work=NBC News|date=27 July 2010}}</ref> but it has yet to pass.<eod>