coercion ... with the exercise or enjoyment by any individual or individuals of rights secured by the Constitution or laws of the United States, or of the rights secured by the Constitution or laws of [California].” Cal. Gov’t -Code § 52.1. To prevail on a § 52.1 claim, a plaintiff must therefore prove (1) a violation of a constitutional or statutory right (2) by intimidation, threats or coercion. Venegas v. Cnty. of Los Angeles, 153 Cal.App.4th 1230, 1242, 63 Cal.Rptr.3d 741, 750 (2007). Defendants take the position that a California Civil Code § 52.1 claim can only survive if the plaintiff proves “threats, intimidation, or coercion” separate and apart from whatever constitutional violation is at issue in the case. See Rodriguez v. City of Fresno, 819 F.Supp.2d 937, 953 (E.D.Cal.2011) (<HOLDING>). Defendants argue that Plaintiffs failed to
holding that where the plaintiffs evidence supported a finding that the defendants had applied force to restrain him the jury must determine not only whether the officers were justified in using force at all but if so whether the degree of force actually used was reasonable holding that an officers use of force against a plaintiff was objectively reasonable considering the force the plaintiff herself exercised in resisting police custody holding force to be an element of pre1994 amendment  111 which may be satisfied by proof of force or threat of force holding that under  521 the coercive force applied against a plaintiff must result in an interference with a separate constitutional or statutory right and it is not sufficient that the right interfered with is the right to be free of the force or threat of force that was applied holding that plaintiff could not pursue section 521 claim on the basis of allegations that defendants used force to interfere with his right to be free from bodily restraint or harm