Sharp v. Cleveland Clinic

Brianna Sharp (plaintiff) was a nurse at the Cleveland Clinic (the clinic) (defendant). Over two months, Sharp withdrew more narcotic medications than she administered. Her manager called a meeting to express concerns about these discrepancies and possible controlled-substance use. Sharp acted nervous but consented to drug testing. Her manager walked her to the clinic’s emergency room, where test samples were taken. Sharp then asked to go home and was told she was free to leave. However, because of concerns about whether Sharp had narcotics in her system, she was told she could not drive her personal car or she would be arrested. Sharp called her boyfriend to pick her up. While Sharp waited in the emergency room’s lobby, clinic nurses observed her. Sharp asked to retrieve a garage-door opener and dirty dishes from her car. Concerned that she might use this request to get to her car and drive, the nurse contacted clinic law enforcement to escort Sharp. A female officer asked Sharp and the nurse to get into the officer’s car and drove them through the parking garage to Sharp’s parked vehicle. Back in the emergency-room waiting area, officers remained nearby. Sharp asked to smoke. An officer told her she had to stay within a certain area to smoke, and a clinic nurse accompanied her. When Sharp’s boyfriend arrived, she left with him. Sharp’s drug tests were negative. The clinic terminated Sharp for performance issues. Sharp sued the clinic in Ohio state court. Among other claims, she alleged that the clinic and its officers had committed the tort of false imprisonment by confining her in the emergency-room lobby and in the police car during the trip to her vehicle. The trial court found the evidence could not reasonably support a valid false-imprisonment claim and granted summary judgment to the clinic. Sharp appealed to the Ohio Court of Appeals.