Wal-Mart Stores, Inc. v. Rodriguez

Summary

The Supreme Court of Texas held that Wal-Mart could not be liable for false imprisonment based solely on its failure to disclose that its check-identification system might provide inaccurate information. Liability for instigating an arrest requires knowingly providing false information to law enforcement that results in the arrest; incomplete or negligently inaccurate information is insufficient. The court reversed the court of appeals in part and rendered judgment for Wal-Mart.

Holdings

1. A private party may be liable for instigating an unlawful arrest when it knowingly provides false information to law enforcement authorities and that information results in the arrest. Merely reporting a crime or identifying a suspect, without clearly directing or requesting the arrest, ordinarily does not establish instigation.
2. Negligently providing inaccurate or incomplete information to law enforcement does not make a reporting party liable for false imprisonment. The plaintiff must show that the defendant knowingly provided false information resulting in the arrest.
3. Rodriguez did not produce more than a scintilla of evidence that Wal-Mart knowingly provided false information or otherwise willfully instigated his arrest. Wal-Mart was therefore entitled to no-evidence summary judgment on the false-imprisonment claim.

Questions Presented

1. Whether a private party instigates a false imprisonment when it reports a suspected crime to law enforcement but negligently provides inaccurate or incomplete information.
2. Whether evidence that Wal-Mart failed to disclose that its check-identification system could produce an erroneous driver's-license number raised a fact issue on willful detention.
3. Whether Wal-Mart was entitled to no-evidence summary judgment on Rodriguez's false-imprisonment claim.

Disposition

reversed