What constitutes force or violence under section 2962 of the California Code of Civil Procedure?

We have previously held that the terms "force" and "violence" as used in section 2962 are not synonymous, and "force" has a broad meaning which encompasses any action by the defendant which overcomes the victim's resistance or implies that force may be used. (People v. Pretzer (1992) 9 Cal.App.4th 1078, 1082-1083, 11 Cal.Rptr.2d 860.) An implied threat that "invite(s) resistance or escape with possible resulting injury" is sufficient to constitute "force." (Id., at p. 1083, 11 Cal.Rptr.2d 860.)

There are limits, however. For example, the standard CALJIC definition of force or violence for purposes of battery--including a " 'slight touching' done in an insolent, rude, or angry manner"--is too broad to lead to potential lifetime confinement. (People v. Collins (1992) 10 Cal.App.4th 690, 696-697, 12 Cal.Rptr.2d 768.)