Smith v. Comair, Inc.
United States Court of Appeals for the Fourth Circuit
134 F.3d 254 (1998)
Relevant factsFree
James Smith (plaintiff) was denied boarding by a Comair/Delta (defendants) representative due to a missing photo ID, was watched by security guards from a distance, and was later briefly restrained by security only after he told the representative he wanted to punch him; he was ultimately allowed to fly home and sued for false imprisonment, and the district court granted the airlines summary judgment.
IssueFree
Whether a claim for false imprisonment requires evidence that the plaintiff was completely restrained against his will without freedom to leave.