The following excerpt is from Cuviello v. City of S.F., 940 F.Supp.2d 1071 (E.D. Cal. 2013):
Defendants' primary argument here is that the requisite showing of threats, intimidation, and coercion is not met here. They cite Shoyoye v. County of Los Angeles, 203 Cal.App.4th 947, 959, 137 Cal.Rptr.3d 839 (2012), for the proposition that, where coercion is inherent in the constitutional violation alleged, i.e., an over-detention in County jail, the statutory requirement of threats, intimidation, or coercion is not met.
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