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Morales v. Lee

Court of Appeals of Texas

668 S.W.2d 867 (1984)

Relevant factsFree

Dr. Cesar Morales (defendant) accused employee Linda Lee (plaintiff) of stealing $5, and when she denied it, shouted, slammed a chart down, told her not to leave, and threatened to call police and have her arrested if she left; Lee feared he might hit her, and Morales then fired her and told her to leave. Lee left his office but waited in the waiting room for her paycheck, visibly shaking and crying, and later suffered ongoing physical distress; a jury found for Lee on her false-imprisonment claim, and Morales appealed.

IssueFree

Whether a threat of future action, by itself, is typically enough to cause false imprisonment.

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