McCann v. Wal-Mart Stores, Inc. case brief

McCann v. Wal-Mart Stores, Inc. case brief summary
210 F.3d 51 (2000)

CASE SYNOPSIS

Defendant appealed a decision by the United States District Court for the District of Maine denying its post-judgment motions for judgment as a matter of law and for a new trial in plaintiff's false imprisonment action. Plaintiffs cross-appealed the district court's pre-trial dismissal of their claim for punitive damages.

CASE FACTS
Plaintiffs sued defendants for false imprisonment. Defendants appealed denial of post-judgment motions for judgment as a matter of law and for a new trial, and plaintiff cross-appealed dismissal of claims for punitive damages. Employees of defendant stopped plaintiffs as they were leaving the store, claiming plaintiff children had been previously caught shoplifting, and could not come back into the store. The employees detained plaintiffs until a security officer determined plaintiff children were not the children previously caught.

DISCUSSION

• The court held plaintiffs adequately proved the elements of false imprisonment. 
• The court held the employees' actions could induce reasonable people to believe they would be restrained physically if they sought to leave, or defendant was claiming lawful authority to confine them. 
• The court held denial of punitive damages proper. 
• The court found refusal to allow a plaintiff to use the restroom was not outrageous, given plaintiff's failure to press the request.

CONCLUSION

The court affirmed the decision, because plaintiffs adequately proved the elements of false imprisonment, and defendant's refusal to allow one plaintiff, a 12-year old boy, to use the restroom was not sufficiently outrageous to warrant the imposition of punitive damages.

Suggested Study Aids For Tort Law