California, United States of America
The following excerpt is from The People v. Bailey, E049041, No. FBA900010 (Cal. App. 2010):
Section 286, subdivision (a) defines sodomy as "sexual conduct consisting of contact between the penis of one person and the anus of another person. Any sexual penetration, however slight, is sufficient to complete the crime of sodomy." A conviction of sodomy under section 286, subdivision (a) therefore requires at least some penetration. (People v. Ribera (2005) 133 Cal.App.4th 81, 85-86.)
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