In Shoyoye v. County of Los Angeles (2012) 203 Cal.App.4th 947, the plaintiff was lawfully arrested but was held more than two weeks after the order for his release; a county employee mistakenly attached information about another person to the defendant's paperwork. (Id. at pp. 951-953.) The plaintiff claimed interference with his constitutional right to be secure against unreasonable seizure. (Id. at p. 955.) Relying on a case which adopted the analysis in Longval v. Commissioner of Correction (1989) 404 Mass. 325 535 N.E.2d 588, the appellate court in Shoyoye held that where coercion is inherent in the constitutional violation alleged, as it is in an unreasonably prolonged detention, section 52.1 requires a showing of coercion independent from the coercion inherent in the wrongful detention. (Shoyoye, supra, 203 Cal.App.4th at pp. 959-960.)