California, United States of America
The following excerpt is from People v. Vales, 2d Crim. No. B259765 (Cal. App. 2016):
Similarly, the use of violence, menace, fraud, or deceit elevates false imprisonment to a felony. ( 237, subd. (a); People v. Castro (2006) 138 Cal.App.4th 137, 140.)2
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