Dale Sullivan Case

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MEMORANDUM To: From: Date: October 11, 2011 RE: Dale Sullivan: False Imprisonment QUESTION PRESENTED Under Texas state law, can an employer be liable for false imprisonment when it detained an employee in a partially glass enclosed room with one door guarded by two men for three hours, threatened the employee with jail time, and repeatedly told the employee that it would not be a good idea for him to leave the room? BRIEF ANSWER Probably yes. For a plaintiff to establish a false imprisonment claim in Texas, he must prove (i.) that the defendant willfully detained him; (ii.) that the act was not consensual; and (iii.) that the defendant was acting without authority of law. Two of the elements here satisfy the claim; the…show more content…
Sullivan will most likely be able to establish that his employer, Lonestar Bank, is liable for false imprisonment. In the state of Texas, to establish a claim for false imprisonment, the plaintiff must prove that (i.) the defendant willfully detained the plaintiff; (ii.) that the defendant detained the plaintiff without lawful authority; and (iii.) that the defendant detained the plaintiff without his consent. Black v. Kroger Co., 527 S.W.2d 794, 795 (Tex. Civ. App. 1975). Mr. Sullivan will probably be able to satisfy the last two elements as determined by another associate of the firm. The only issue in question that Mr. Sullivan will have to satisfy is whether Lonestar willfully detained him. The court will probably find that Mr. Sullivan was willfully detained by his employer, Lonestar bank, because he was brought to a glass room where the door was guarded by two men who threatened him not to leave the room and watched him as he was only allowed to go to the…show more content…
Randall’s, 891 S.W.2d at 645. It has also held that “an employer must be able to suggest, and even insist, that its employees perform certain tasks in certain locations at certain times.” Id. In Randall’s v. Johnson, the court held that even though the employee was given a suggestion to stay in a particular place and avoid the sales floor, she was not willfully detained. Id. There, an employee was escorted by another superior employee on behalf of her supervisor, and she was told to wait in the supervisor’s office where she would be questioned about the theft of a wreath. Id. at 643. She was left in the office unguarded and exited the office twice to use the restroom and visit another employee. Id. at 645. The court reasoned that she was not guarded or prevented from exercising her free will to move from place to place, and the supervisor was acting in a customary manner when he gave her the choice to perform a task or wait in an office; therefore, she was not willfully detained. Id. Likewise, in Safeway v. Amburn, the court held that an employer did not willfully detain an employee when the employer confronted him in a logical place without restraint about a matter bearing upon the duty of his job. Safeway Stores, Inc. v. Amburn, 388 S.W.2d. 443, 446 (Tex. Civ. App. 1965). There, an employee was taken to a conference room in a secluded

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