to consent and, therefore, sexual conduct with a minor is per se against that minor’s will. Gov’t Position (d/e 172) at 4. However, the proscribed age of consent in Illinois is generally 17. People v. Lloyd, 369 Ill.Dec. 759, 987 N.E.2d 386, 393. (2013). The Government does not explain why the Illinois legislature would require use of force for victims who are at least 13 years of age but under 17 years of age if the lack of capacity to consent constitutes inherent use of force. Moreover, Section 2241(a)(1) requires the actual use of force. See United States v. Cherry, 938 F.2d 748, 754 (7th Cir.1992) (noting that “[i]f actual force is used, the defendant is guilty of aggravated sexual abuse under 18 U.S.C. § 2241(a)(1)”); United States v. Archdale, 229 F.3d 861, 868 (9th Cir.2000) (<HOLDING>) (citations and quotations omitted). The
holding that the decision of a police officer to preserve public safety and order through use of commands backed by threat of force or actual use of physical force is a matter of discretion holding that  2241a1 requires actual use of force meaning use of such physical force as is sufficient to overcome restrain or injure a person holding that a texas assault statute requiring that the defendant intentionally knowingly or recklessly causes bodily injury to another  may be violated by the defendant so causing such injury by means other than the actual attempted or threatened use of physical force against the person of another and hence does not have such use of force as an element alteration in original recognizing that an arrest requires either physical force  or where physical force is absent submission to the assertion of authority holding that expert testimony on what constitutes deadly physical force and whether the use of force was justified should have been excluded