Bonkowski v. Arlan’s Department Store

Bonkowski (plaintiff) shopped at Arlan's Department Store (defendant) and, as she and her husband walked to their car, a store officer approached and asked her to return, saying someone reported she had put jewelry in her purse without paying. She denied it, emptied her purse, produced receipts, and was released. She sued the store and officer for false arrest and slander, and a jury found for her. The defendants appealed.

Whether a merchant may be held liable for false arrest for detaining a suspect in the immediate vicinity of the store for a reasonable investigation of suspected shoplifting.