Romanski v. Detroit Entertainment, L.L.C.

428 F.3d 629 (2005)

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Romanski v. Detroit Entertainment, L.L.C.

United States Court of Appeals for the Sixth Circuit
428 F.3d 629 (2005)

  • Written by Brett Stavin, JD

Facts

On August 7, 2001, 72-year-old Stella Romanski (plaintiff) visited a casino owned by Detroit Entertainment L.L.C. (the casino) (defendant) with her friends. Romanski noticed an abandoned five-cent token in the tray of a slot machine with no chair in front of it. Romanski picked up the token and intended to use it to play at one of the other machines. A uniformed security guard then approached Romanski and asked her to come to the office. Upon arriving at the office, three more guards surrounded her, and one of the guards, Marlene Brown (defendant), explained that Romanski’s conduct, known as slot-walking, violated an unpublished casino policy. According to Brown, Romanski became belligerent, resulting in her being escorted to a small windowless room off the casino floor. Brown described herself as a security police officer and accused Romanski of theft. Unknown to Romanski at the time, Brown and certain other security officers were licensed under Michigan law as private-security police officers authorized to make arrests. Brown escorted Romanski to the valet area, denied Romanski’s request to meet her friends at the lunch buffet, and only allowed Romanski to use the restroom if accompanied by a guard outside the stall. Romanski filed a state court action against the casino and the guards, claiming a violation of her Fourth Amendment right against wrongful arrest under 42 U.S.C. § 1983. After removal of the case to federal court, a jury ruled in Romanski’s favor, awarding $279.05 in compensatory damages. Romanski was also awarded $500 and $875,000 in punitive damages against Brown and the casino, respectively. The casino and Brown appealed, arguing that their actions did not arise under color of state law for the purposes of § 1983, that the token was not abandoned, and that the punitive damages were excessive.

Rule of Law

Issue

Holding and Reasoning (Clay, J.)

Dissent (Farris, J.)

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