Street v. Shoe Carnival, Inc.

STATON, Judge,

dissenting.

I dissent. In order to succeed on their false imprisonment claims, Street and Heise had to establish the absence of probable cause for their arrest. Probable cause for criminal prosecution exists when facts found on reasonable inquiry would induce a reasonably prudent and intelligent person to believe that the accused committed the charged crime. Duvall v. Kroger Co. (1990), Ind.App., 549 N.E.2d 403, 405. Although probable cause is generally a factual question reserved for the jury, it is a question of law when the facts are undisputed. Id. at 405-406 (citing Costello v. Mutual Hospital Ins. Inc. (1982), Ind.App., 441 N.E.2d 506, 509, reh. denied, trans. denied ).

In this case, the facts relevant to the issue of probable cause are undisputed. It is undisputed that Street concealed merchandise and that Heise observed her doing so. It is further undisputed that both carried merchandise beyond the point of payment. These acts constitute prima facie evidence that they committed theft; that is, they exerted unauthorized control over and intended to deprive Shoe Carnival of the merchandise. IND.CODE § 35-48-4-4(c) (1998). These undisputed facts alone are sufficient to constitute probable cause, rendering the detention lawful and defeating Street and Heise's *1061false imprisonment claim.1 Duvall, supra, at 407.

Further, the trial court in the criminal proceeding found probable cause for Street and Heise's arrest. Judicial determinatipn of probable cause constitutes prima facie evidence of probable cause in this civil action. See Lazarus Department Store v. Sutherlin (1989), Ind.App., 544 N.E.2d 513, 520, trans. denied (determination of probable cause in criminal case prima facie evidence of probable cause in subsequent malicious prosecution action). Street and Heise could rebut this only by presenting evidence that the probable cause determination was induced by false testimony or fraud. Id.

Although Street and Heise contend that Wright's conduct was inappropriate and that he coerced them into signing confessions, they do not present evidence to dispute Wright's statements regarding the concealment of merchandise beyond the point of payment. Accordingly, they did not successfully rebut Shoe Carnival's prima facie evidence of probable cause. Because the facts demonstrating the existence of probable cause are undisputed, summary judgment was properly entered on this count. The trial court should be affirmed.

I also dissent to reversal of summary judgment on Street and Heise's defamation claim. Although the Majority correctly states the general rule that determining whether a communication is defamatory is a question of law, the Majority goes on to conclude that because the communication at issue here is reasonably susceptible to either a defamatory or non-defamatory interpretation, it is a factual issue precluding summary judgment. Maj. op. at 1058-1059 (citing Rambo v. Cohen (1992), Ind.App., 587 N.E.2d 140, 145, trans. denied ). I disagree.

Street and Heise argue that statements by Wright were defamatory per se because his statements imputed to them commission of a crime. Upon detaining Street and Heise in the store, Wright made the following statement: "resisting arrest call 911 hurry. Resisting arrest." This communication is not reasonably susceptible to a defamatory interpretation. In order for the false imputation of eriminal activity to give rise to a cause of action for defamation, the imputation must bear a reasonably close relation to the legislative definition of a crime.2 Chestnet v. K-Mart Corp. (1988), 529 N.E.2d 131, 135, trans. dismissed. The mere statements "resisting arrest" and "call 911" bear no relation to the legislative definition of any crime; thus, they are not defamatory per se. Because Wright's statements are not reasonably susceptible to a defamatory interpretation, summary judgment on this issue was appropriate.

As the Majority correctly states, compensatory damages are a prerequisite to an award of punitive damages. Maj. op. at 1060 (citing Sullivan v. American Cas. Co. of Reading, Pa. (1992), Ind.App., 605 N.E.2d 134, 140). Because I would conclude that Shoe Carnival was entitled to summary judgment on the false imprisonment and defamation claims, it logically follows that Shoe Carnival would pay neither compensatory nor punitive damages on those claims. Thus, summary judgment was proper on the punitive damage claim.

*1062Because I would affirm the trial court in all respects, I dissent.

. The Majority relies on Street and Heise's explanation for concealing merchandise beyond the point of payment to create a genuine issue of material fact in this case. Although Street and Heise's explanation for their conduct is relevant to whether they actually committed theft, it is not material to the issue of probable cause. Their undisputed conduct alone, regardless of the explanation therefor, is sufficient to constitute probable cause and precludes a false imprisonment claim. See IC 35-43-4-4(c), Duvall, supra.

. The Majority rejects this well-established rule based on Seller v. Jenkins (1884), 97 Ind. 430, 431, in which our supreme court stated that "lilt is not necessary that the words uttered should be such as to describe the offence imputed by them with technical accuracy." Id. at 431. The defamatory statement in Seller was that Seller "took his old root out and pissed before the women." Id. at 432. Although this statement does not technically describe the offense of indecent exposure, it does bear a reasonably close relationship to that crime. In contrast, the statement at issue in this case is vague and ambiguous, and does not bear a relationship to any particular crime.