Jason Markeith Thompson (defendant) worked as a caretaker for the residents of a group home for developmentally disabled individuals. One of Thompson's duties was to protect the residents from harm. The State of California (plaintiff) prosecuted Thompson for raping one of the residents, a woman with Down syndrome. At trial, the prosecution produced ample evidence of the woman's limited cognitive ability and "childish" understanding of sexual matters. The relevant statute defined rape as including sex with a victim who, at the time, is so developmentally disabled as to make valid consent impossible, provided the perpetrator knows or has reason to know of the disability. Thompson alleged that there was insufficient evidence to show that the woman was incapable of giving legal consent. A jury convicted Thompson and he appealed to the California Court of Appeal.