The United States Federal law does not list a specific criminal determination for consensual BDSM acts. Many BDSM practitioners cite the legal decision of "People v. Jovanovic", 95 N.Y.2d 846 (2000), or the "Cybersex Torture Case", which was the first U.S. appellate decision to hold (in effect) that one does not commit assault if the victim consents. However, many individual states do criminalize specific BDSM actions within their state borders. Some states specifically address the idea of "consent to BDSM acts" within their assault laws, such as the state of New Jersey, which defines "simple assault" to be "a disorderly persons offense unless committed in a fight or scuffle "entered into by mutual consent", in which case it is a petty disorderly persons offense".