text: United States, Maryland: Maouloud Baby v. State of Maryland (aka Maryland v. Baby) is a Maryland state court case relating to the ability to withdraw sexual consent. The jury in the trial court convicted Baby of first degree rape and related charges, but the Court of Special Appeals, based upon a 1980 precedent that held that a rape could not legally occur if a woman withdrew consent after penetration, reversed the conviction. That precedent interpreted the English common law such that the withdrawal of consent following initial penetration did not make the act a rape. The court noted other states had noted that the act of intercourse is not completed at the initial penetration, and so consent could be withdrawn at any point during intercourse. For rape, the court noted that force or threat of force was a necessary element of the crime. Due to issues involving the instructions to the jury regarding rape and consent, the case was remanded for a new trial. In 2008, the Court of Appeals affirmed the Court of Special Appeals' reversal of the convictions and remand for re-trial, due to the trial court's error in failing to answer the jury's questions about whether a sex act continued after the withdrawal of consent could constitute rape if penetration had already occurred. However, the court ruled that consent could be withdrawn at any time, even if the victim had initially consented.
  United States: In 2008 the Federal Bureau of Prisons mandated that in all federal correctional facilities, "inmates in labor, delivery, or post-delivery recuperations shall not be placed in restraints unless there are reasonable grounds to believe the inmate presents an immediate serious threat of hurting herself or others, or there are reasonable grounds to believe the inmate presents an immediate and credible risk of escape."