California, United States of America
The following excerpt is from People v. Delgado, 2 Cal.5th 544, 214 Cal.Rptr.3d 223, 389 P.3d 805 (Cal. 2017):
(People v. Thomas (2011) 52 Cal.4th 336, 363, 128 Cal.Rptr.3d 489, 256 P.3d 603.) Charging at correctional officers and attempting to bowl them over while holding a mattress as a shield constitutes a serious threat of force; so too does grabbing a large canister of pepper spray and using it to shatter the security window of a prison cell.
[389 P.3d 834]
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