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I mean, the courts ruled that he raped E. Jean Carroll, even without penile insertion. The legal definition of rape largely depends on where the crime is committed; In some jurisdictions, it requires PiV sex. In others, it can be as simple as unwanted intimate contact.
The judge in that case clarified that even though he was “only” found liable for sexual battery, what he did (groping her breasts and inserting his fingers into her vagina without her consent) would colloquially be known as rape. Even though it didn’t fit the strict legal definition for the jurisdiction (which required penile insertion) the average layperson would still consider his act to be rape. This clarification was after he tried to sue her for defamation, when she publicly said she won the rape case against him.