In Maher v. Wilson (1903) 139 Cal. 514, the plaintiff recovered only nominal damages for being falsely imprisoned, given that no actual damages were sustained and there was no evidence of oppression, fraud, or malice. (Id. at pp. 519-520.) Although the defendants in Maher had caused the plaintiff's forcible removal and arrest, the court found that the mere use of force does not constitute evidence of oppression, fraud, or malice where only a reasonable and necessary amount of force was used in the detention. (Id. at p. 519.)