Hunt v. State
Supreme Court of Delaware
69 A.3d 360 (Del. 2013)
School resource officer David Pritchett (defendant), already convinced a different fifth-grader (AB) had stolen money from an autistic student, nonetheless pulled Anthony Hunt (plaintiff) into a closed room without the vice principal's permission and, alongside AB, questioned him in a harsh voice, telling him 11 separate times that he could be arrested and jailed for lying — even though Pritchett had told Hunt beforehand that he didn't think AB had actually taken the money. Hunt was visibly shaken by the roughly hour-long questioning, after which AB confessed. Hunt, through his mother (plaintiffs), sued Pritchett and others under 42 U.S.C. §1983 and state tort law for intentional infliction of emotional distress (IIED), false imprisonment, and battery; the trial court granted Pritchett summary judgment on all claims, and Hunt appealed.
Whether a school resource officer may be held liable for intentional infliction of emotional distress, false imprisonment, and a Fourth Amendment seizure for detaining and repeatedly threatening a student the officer already believed to be innocent.