Ruszala v. Walt Disney World Co.

Bill Ruszala (plaintiff), a Walt Disney World Co. (Disney) (defendant) employee, was interrogated and confessed to theft after Disney security investigators reported him to the Orange County sheriff's office; Corporal Robert Stephens then arrived, advised Ruszala of his rights, stopped questioning when Ruszala asked for a lawyer, and arrested him. Ruszala sued Disney, security investigator Dennis Ramos, and Sheriff Kevin Beary (defendants), including a § 1983 civil-rights claim against Beary premised solely on the theory that Stephens relied on Disney employees' word rather than his own personal knowledge in finding probable cause. Beary's attorney sent Ruszala's lawyer two letters asking that Beary be dropped from the suit and warning that Beary would seek his costs for defending a frivolous claim; Ruszala later admitted in deposition that probable cause existed for his arrest, and the court granted Beary's motion for summary judgment before ordering Ruszala and his lawyer to show cause why they shouldn't pay Beary's costs and fees.