Serv. Cos. v. Estate of Vaughn - 169 So. 3d 875 (Miss. 2015)

Rule:

Both false imprisonment and intentional infliction of emotional distress (as a result of the imprisonment) require willful, and not merely negligent, acts by the tortfeasor.

Facts:

Mautrice Vaughn's estate brought suit for false imprisonment and intentional infliction of emotional distress against The Service Companies Inc., ("FSS"), following Vaughn's fatal heart attack at work. The plaintiffs alleged Vaughn's supervisor would not let her leave work to see a doctor despite complaints of severe chest pain and a headache. FSS moved for dismissal under Mississippi Rule of Civil Procedure 12(b)(6). In its motion, FSS argued the plaintiffs could not recover for an injury sustained at work under the Mississippi Wrongful Death Statute, as the Mississippi Workers' Compensation Act (MWCA) provided the exclusive remedy against an employer. The plaintiffs opposed the motion, arguing their claims were excepted from the MWCA as intentional torts. The MWCA, they argued, exclusively governed only common-law claims for negligence. Without explanation, the circuit court entered an order denying FSS's Motion to Dismiss. Subsequently, FSS moved for summary judgment, asserting that without an “actual intent to injure” Vaughn, the plaintiffs could not proceed on a claim outside of the MWCA. The circuit court issued an order denying summary judgment to FSS. FSS appealed. 

Issue:

Could the plaintiffs proceed on their claim even without a showing of the employer’s actual intent to injure the deceased employee? 

Answer:

No.

Conclusion:

The court held that the circuit court erred in denying FSS’s motions for summary judgment and to dismiss because plaintiffs failed to submit evidence of actual intent to injure the employee as an essential element of their false-imprisonment claim, where none of the parties alleged that the employee's manager or the employer would have fired the employee if she left work, and the plaintiffs’ counsel did not sufficiently evidence, through case law or otherwise, that such an action would amount to willful detention in any event.