Teel v. May Department Stores Co.
Supreme Court of Missouri
155 S.W.2d 74 (1941)
Teel (plaintiff) accompanied her sister-in-law Leona on a shopping trip to a store owned by May Department Stores Co. (May Co.) (defendant), where Leona fraudulently charged large purchases to another woman's account by posing as her. After the store's detective and credit manager confronted Leona and exposed the fraud, Teel returned the merchandise that had already been carried to Leona's car. Despite the property being recovered, the detective refused to let Teel and Leona leave his office until each signed a confession. Teel sued May Co. for false arrest and imprisonment, and the jury -- instructed that any detention beyond what was necessary to recover the merchandise was false imprisonment -- awarded Teel $1,000. Both sides appealed, Teel over the amount and May Co. over the denial of a directed verdict and the jury instructions.
Whether a store that has already recovered its property from a suspected shoplifter may continue to detain that person, including to obtain a signed confession.