In what circumstances will a court overturn a finding of false imprisonment and violation of civil rights under Civil Code section 52.1?

In Shoyoye v. County of Los Angeles (2012) 203 Cal.App.4th 947, however, our colleagues in Division Four of this court recently issued an opinion involving facts and issues significantly similar to those in the instant appeal. Shoyoye was properly arrested, but he was detained in the jail for a longer period than required by law. On the basis of the evidence of his over-detention, the jury rendered verdicts in his favor on his allegations of false imprisonment and violation of his civil rights under Civil Code section 52.1. The court affirmed the judgment in his favor on false imprisonment but reversed the judgment as to the civil rights violation. (Shoyoye, supra, at p. 963.)

The Shoyoye court concluded "that where coercion is inherent in the constitutional violation alleged, i.e., [a false imprisonment], the [Civil Code section 52.1] 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." (Shoyoye v. County of Los Angeles, supra, 203 Cal.App.4th at p. 959.) The court determined there was no evidence of any coercion independent of that inherent in false imprisonment. To constitute a violation of Civil Code section 52.1, according to the court, the requisite interference with the plaintiff's constitutional rights must be intentional, that is "deliberate or spiteful." (Shoyoye, supra, at p. 959.) The Shoyoye court stated, "The apparent purpose of the statute is not to provide relief for [a false imprisonment] brought about by human error rather than intentional conduct." (Ibid.)