What is the test for liability under section 52.1 of the California Civil Rights Code for threats, intimidation or coercion?

California, United States of America

The following excerpt is from Hall v. City of Fremont, A147651 (Cal. App. 2017):

Hall first argues that a decision issued before ShoyoyeVenegas v. County of Los Angeles (2004) 32 Cal.4th 820 (Venegas)stands for the proposition that section 52.1 liability extends to any civil rights violation accompanied by threats, intimidation, or coercion. She then contends that Shoyoye's requirement of threats, intimidation or coercion independent from the coercion inherent in the wrongful detention is limited to unintentional civil rights violations.

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