What is the test for determining whether there was force between the parties in a sexual assault case?

^4. The juvenile court also found that "the evidence is clearly beyond a reasonable doubt that there was force," but did not identify the evidence supporting this finding. However, force is defined as " 'physical force substantially different from or substantially greater than that necessary to accomplish the lewd act itself.' " (People v. Bolander (1994) 23 Cal.App.4th 155, 158-159, disapproved on other grounds in People v. Soto (2011) 51 Cal.4th 229, 248, fn. 12 (Soto).) Here, there is no evidence of force and the Attorney General does not contend otherwise.