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Failing to make a full and fair disclosure is not the equivalent of knowingly providing false information. All citizens have a clear legal right to report criminal misconduct to law enforcement authorities. Although a private citizen may be liable for directing an arrest that results in a false imprisonment, the law will not generally permit inferring such direction simply from a report of crime made to the authorities. Such an inference is justified when a party provides information in its report that it knows is false. Merely providing inaccurate or incomplete information, however, will not make a party liable for instigating a subsequent false imprisonment.
Martin Rodriguez purchased supplies for his employer, using a company check. Because he was the first to present his employer's company check there, the cashier requested personal identification. He offered his driver's license, and the cashier entered his license number into the store's check identification system. Any company check presented thereafter would be approved without a prompt for further identification. After he left his job, a company check was presented and returned due to insufficient funds. Police stopped him, and the officer found a warrant issued for his arrest on theft by check. After the charges against him were dismissed, he sued the store. The instant court was asked to decide whether the store could be liable for false imprisonment because of its failure to disclose that its check identification system could provide inaccurate information, resulting in an innocent person's arrest. The trial court said no; the court of appeals said yes.
May Wal-Mart be liable for false imprisonment because of its failure to disclose to the district attorney that its check identification system could provide inaccurate information, resulting in the arrest of innocent persons?
The court held that Wal-Mart cannot be held liable for false imprisonment because there is no evidence that it knowingly provided the district attorney with false information intending that Rodriguez be arrested.