California, United States of America
The following excerpt is from Sherman v. Bryant, E072201 (Cal. App. 2020):
In Shoyoye v. County of Los Angeles (2012) 203 Cal.App.4th 947, which involved a lawful arrest followed by an overly long detention, the court held "that where coercion is inherent in the constitutional violation alleged, i.e., an overdetention in County jail, the statutory requirement of 'threats, intimidation, or coercion' is not met. The statute requires a showing of coercion independent from the coercion inherent in the wrongful detention itself." (Id. at p. 959.)
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