Zavala v. Wal-Mart Stores, Inc.

Undocumented immigrant janitors (plaintiffs) who worked at Wal-Mart (defendant) stores brought a class action alleging, among other claims, false imprisonment. They said Wal-Mart locked them inside its stores during their shifts and also threatened to have them deported. Wal-Mart moved to dismiss.

Whether the tort of false imprisonment requires that the plaintiff be confined by force or the threat of force, such that locking workers inside a store or threatening them with deportation can state a claim.