The following excerpt is from Dillman v. Tuolumne Cnty., 1:13-CV-00404 LJO SKO (E.D. Cal. 2013):
Defendants cite Shoyoye v. County of Los Angeles, 203 Cal. App. 4th 947, 959 (2012), for the proposition that the statute requires a showing of coercion independent from the coercion inherent in the wrongful detention itself. Doc. 9-1 at 12. A recent Northern District of California case thoroughly discusses Shoyoye and explains why it should not be read as requiring a separate showing of coercion:
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