How have courts interpreted the meaning of "violence" in section 237 of the California Penal Code?

imprisonment." ' [Citation.] [] As to the felony's elements, the jury was instructed . . . that 'Violence, within the terms of this instructions [sic] means the exercise of physical force used to restrain over and above the force reasonably necessary to effect such restraint. [] Menace means a threat of harm express or implied by word or by act.' ... The instruction's distinction between violence and force is consistent with dictum in People v. Arvanites (1971) 17 Cal.App.3d 1052, 1059-1060 and footnote 7, where the court noted that a contrary statutory interpretation, rendering 'violence' synonymous with 'force,' would allow the felony offense to largely swallow up the misdemeanor. We agree and conclude the instruction accurately states the meaning of 'violence' in section 237. [Citation.]" (People v. Babich (1993) 14 Cal.App.4th 801, 806-807 (Babich); see also People v. Hendrix (1992) 8 Cal.App.4th 1458, 1462 [noting the trial court erred when it found that "force was solely an element of felony false imprisonment," as misdemeanor false imprisonment also requires force but "becomes a felony only where the force used is greater than that reasonably necessary to effect the restraint"].)