Rougeau v. Firestone Tire & Rubber Co.

Brief Fact Summary.

Defendant thought that Plaintiff stole two lawnmowers for its plant. Plaintiff was instructed to wait inside the guardhouse with two guards, but was allowed to leave after about thirty minutes, when he fell ill. Plaintiff sued Defendant for false imprisonment. The trial court ruled in favor of Defendant. Plaintiff appealed.

Synopsis of Rule of Law.

The tort of false imprisonment is the intentional confinement of another within a specific area and against his will.

Facts.

Rougeau (Plaintiff) was employed as a guard and fireman at Firestone Tire & Rubber Company’s (Defendant) plant in Lake Charles, Louisiana. During his shift at the plant, two lawn mowers were stolen and plant personnel suspected Plaintiff took them. Defendant’s corporate security manager and two of his employees accompanied Plaintiff to his home to search for the missing property. On the advice of his attorney, Plaintiff refused to allow the search of his property. After returning to the plant, Plaintiff was asked to wait inside the guardhouse while a search of the area was conducted. Two guards were instructed to keep Plaintiff in the guardhouse, but Plaintiff was allowed to leave when he fell ill. The total time Plaintiff spent inside the guardhouse was about thirty minutes. Plaintiff sued Defendant for false imprisonment. The trial judge denied recovery to Plaintiff and he appealed.

Issue.

Whether the tort of false imprisonment is the intentional confinement of another within a specific area and against his will.

Held.

Yes. The trial court’s ruling is affirmed. The tort of false imprisonment is the intentional confinement of another within a specific area and against his will.

Discussion.

To constitute false imprisonment, an individual must be constrained against his will and not allowed to leave the area of confinement for a significant period of time. Here, at no time was Plaintiff not allowed to leave the guardhouse. Moreover, Plaintiff never informed anyone that he refused to stay in the guardhouse, thus indicating his implied consent to stay.