The widest definition of the term sodomy remained that found in Burchard of Worms’s Decretum, which had unsystematically and uncritically noted every possible act, suggesting that the confessor had the widest latitude in imposing penance. Many of the deeds mentioned, like the use of a dildo, mutual masturbation, anal entry, sex between brothers, and oral sex, which may be regarded as acts against nature because they frustrate conception, are rarely mentioned in the other penitentials. Furthermore, since Burchard quotes many conflicting sources and the possible penalties are so varied, the confessor is given virtual free rein to use his discretion. The penalties range from ten days for masturbation to fifteen years for sexual relations between brothers; the penalty for lesbian acts is typically lower than for homosexual acts between men.

Michael Goodich, The Unmentionable Vice: Homosexuality in the Later Medieval Period (64)