 A further complicating question is whether the criminal law’s usual requirement of mens rea (or “guilty mind”) should apply to rape and, if so, how that requirement should be interpreted. In the most general terms, a mens rea requirement means that the prosecution must show not only that nonconsensual sex occurred, but also that the man was in a certain state of mind with regard to the woman’s lack of consent. Just what that state of mind is—what counts as mens rea in cases of rape—is a matter of some dispute (Burgess-Jackson 1996, 137–161).