Donald Braswell v. Melody Wollard and Dolgencorp, LLC

Summary

The Pennsylvania Superior Court reversed in part a summary judgment order favoring Melody Wollard and Dolgencorp, LLC, in claims arising from Braswell’s arrest after a dispute over change at a Dollar General store. The court held that the evidence could support jury findings that Wollard knowingly made a false report and that her statements were a determining factor in the arrest and subsequent prosecution. The court remanded the claims for malicious prosecution, false arrest, and false imprisonment for further proceedings, affirming the order in all other respects.

Holdings

1. Summary judgment was improper because the evidence permitted a jury to infer that Wollard knowingly made a false report to police, and the question of her knowledge and intent depended on credibility determinations for the jury.
2. Summary judgment was improper on the probable-cause and procurement elements because, if Wollard knowingly supplied false information, her accusation could have been the determining factor in the officer's decision to arrest Braswell, and the officer could not be treated as having exercised independent discretion based on reliable evidence apart from that accusation.
3. Under Pennsylvania law as interpreted by the court, a private party may be liable for false arrest or false imprisonment when the party knowingly provides false or misleading information that causes police to detain the plaintiff, even though the private party did not personally take the plaintiff into custody.
4. Summary judgment must be denied where the evidence permits conflicting inferences on material facts or requires credibility determinations.

Questions Presented

1. Whether genuine issues of material fact precluded summary judgment on Braswell's malicious prosecution claim, including whether Wollard knowingly made a false report, whether the report caused the prosecution, and whether the prosecution lacked probable cause.
2. Whether a private party who allegedly supplies knowingly false information that causes police to arrest another may be liable for false arrest and false imprisonment under Pennsylvania law.
3. Whether the trial court improperly resolved credibility and competing factual inferences on summary judgment.

Disposition

reversed_and_remanded