Hunt v. State

Brief Fact Summary.

Plaintiff was questioned by Defendant, a school officer, about taking money from an autistic child. Defendant placed Plaintiff in a room, closed the door, and proceeded to aggressively question Plaintiff while another juvenile was in the room. The other juvenile later confessed to taking the money from the autistic child. Plaintiff brought suit against Defendant contending that Defendant violated Plaintiff’s civil rights under 42 U.S.C. § 1983 and was also liable intentional infliction of emotional distress, false imprisonment, and battery under Delaware tort law. Defendant motioned for summary judgment, and the trial court granted the motion. Plaintiff appeals.

Synopsis of Rule of Law.

When a school officer uses extreme and outrageous conduct to detain and question a child that is under his or her authority, the school officer may be liable for intentional infliction of emotional distress.

Facts.

David Pritchett, Defendant, was previously a Delaware state trooper and school-resource officer. David McDowell, the vice principal of an elementary school, requested thatDefendant question a fifth-grade student, AB, about an accusation that AB took money from an autistic student. When Defendant questioned AB, AB told Defendant that another student, Anthony Hunt, Plaintiff, took the money from the autistic student.Even though Defendant was certain that AB was the offender, Defendant took Plaintiff to a room without McDowell’s consent, closed the door, and proceeded to question Plaintiff with AB present. Before entering the room, Defendant told Plaintiff that he did not believe AB took the money from the other student.While questioning Plaintiff, Defendant allegedly used an aggressive voice and told Plaintiff 11 times that Defendant could arrest Plaintiff and place him in jail if he lied. Plaintiff was noticibly shaken. Thereafter, AB confessed to taking the money. Plaintiff, by and through his mother, Lisa De Sombre, filed suit against the State of Delaware, Defendant, and other defendants contending that Defendant violated Plaintiff’s civil rights under 42 U.S.C. § 1983 and was also liable intentional infliction of emotional distress, false imprisonment, and battery under Delaware tort law. Thereafter, Plaintiff’s claims against all of the defendants except for Defendant were resolved. Defendant motioned for summary judgment, and the trial court granted the motion. Plaintiff appealed.

Issue.

Whether school officer who uses extreme and outrageous conduct to detain and question a child that is under his or her authority may be liable for intentional infliction of emotional distress.

Held.

Yes, school officer who uses extreme and outrageous conduct to detain and question a child that is under his or her authority may be liable for intentional infliction of emotional distress.

Discussion.

When a school officer uses extreme and outrageous conduct to detain and question a child that is under his or her authority, the school officer may be liable for intentional infliction of emotional distress. Here, although reasonable minds could disagree regarding Defendant’sactions, the evidence indicates that Defendant detained Plaintiff by placing him in a closed room and threatening to arrest Plaintiff and place him in jail eleven times. Even though some high-school students in similar circumstance may have responded in a different manner, here, Plaintif was noticeably shaken by Defendant’s actions. Thus, Plaintiff’sintentional infliction of emotional distress claim survives summary judgment. Additionally, under 42 U.S.C. § 1983, Plaintiff must show that Defendant violated Plaintiff’s civil rights, Defendant was acting under the color of state law whenPlaintiff wasdetained and questioned, and is not shielded by qualified immunity. Pursuant to the Fourth Amendment, one has a right to be free from unreasonable seizures. A seizure occurs when a reasonable person would have believed that he or sheis not free to leave a room while in the presence of a law-enforcement officer. In this case, a reasonable person would believe that Plaintiff was not free to leave the room while Defendant was questioning him. Furthermore, Defendant was certain that Plaintiff was not involved in the event and thus Defendant did not have a reasonable claim to detain Plaintiff for approximately an hour of questioning. Therefore, the seizure was unreasonable and unjustified.Also, to overcome qualified immunity, Plaintiff must demonstrate that Defendant’s conduct was clearly unlawful in this specific situation. In this case,that facts indicate that, Defendant, a law-enforcement officer, interrogated Plaintiff for the sole purpose of intimidating him to force AB to finally confess to the scheme. This form of behavior is not given the protections provided under qualified immunity. Therefore, Plaintiff’s false-imprisonment claim survives summary judgment for similar reasons. Nonetheless, Plaintiff’s state-law battery claim is not substantiated by the record and does not survive summary judgment. Overall, the trial court’s holding is affirmed in part, reversed in part, and remanded for further proceedings consistent with this opinion.