McIntosh v. Arkansas Republican Party-Frank White Election Committee

Robert McIntosh (plaintiff), a Black political activist, bought a ticket to a luncheon in the Little Rock Convention Center’s banquet hall honoring Arkansas governor Frank White. The luncheon was sponsored by the Frank White Election Committee (defendant) and the Arkansas Republican Party (defendant). McIntosh sent a letter to White demanding to speak at the luncheon. Curtis Finch, Jr., the luncheon’s organizer, was concerned because McIntosh had not been invited to speak, he was one of White’s most vocal opponents, and he had sent harassing articles to White. Furthermore, McIntosh had disrupted other events with unsolicited and unwelcome speeches. Before McIntosh could enter the banquet hall, Finch informed him that he was not allowed to attend and offered him a full refund. However, McIntosh refused and insisted that he had the right to attend. The exchange between McIntosh and Finch became heated but did not lead to shouting. Then two state troopers providing security, who were aware that McIntosh might try to disrupt the event, informed McIntosh that he could not attend and asked him to leave. The officers further told McIntosh that if he insisted on entering the banquet hall, he would be arrested. McIntosh replied that the officers should take him to jail. The officers then arrested McIntosh and took him to the North Little Rock jail, where he was charged with disorderly conduct. He was detained and interrogated for two hours until the luncheon ended. McIntosh sued the Frank White Election Committee and the Arkansas Republican Party for false arrest and false imprisonment. The district court dismissed McIntosh’s claims. McIntosh also brought a § 1983 claim based on false arrest, but the district court did not rule on that claim. McIntosh appealed the legal standard of recovery applied by the district court.