How has the pleading standard been interpreted in civil civil cases in the context of civil civil litigation?

9 Branch I 's response to this tension was to follow those courts which have adopted a heightened pleading standard under these circumstances, and have required plaintiffs suing public officials to plead with particularity facts supporting their allegations of unlawful intent. 937 F.2d at 1385-86. That holding was recently affirmed by this court in Branch v. Tunnell, 14 F.3d 449 (9th Cir.1994) (Branch II ).

10 California v. Hodari D., 499 U.S. 621, 111 S.Ct. 1547, 113 L.Ed.2d 690 (1991), relied on by the district court, is not contrary. Id. at 626, 111 S.Ct. at 1550-51 (physical force constitutes a seizure under the Fourth Amendment).