Smith v. Comair, Inc.

During a layover at the Cincinnati, Ohio airport, James Smith (plaintiff) was told by a representative from Comair, Inc. and Delta Airlines, Inc. (defendants), that he could not board his connecting flight. The representative did not give a reason to Smith regarding why he could not board the airplane. Also, Smith noticed two security guards standing approximately 70 feet away, observing him. Several hours later, Smith was informed that he was detained because company employees failed to get photo identification from Smith during the check-in process in Roanoke, Virginia. Because Smith had left his wallet in his vehicle at the Roanoke airport, he did not have the required identification to present to the defendants. However, Smith offered to have his physical description faxed by the Virginia Department of Motor Vehicles or to have defendants obtain his wallet and fly it to Cincinnati. The representative declined Smith’s offer. Later, Smith was given a ticket to return to Roanoke. While waiting to board the return flight, Smith told the representative that he wanted to punch him. Two security guards, one of whom was a police officer, briefly restrained Smith. The representative told the security guards to remove Smith from the airport. However, the security guard who was a police officer convinced the representative to allow Smith to fly to Roanoke. Smith filed suit against the defendants in state court alleging false imprisonment. The action was removed to federal district court. The district court granted summary judgment to the defendants on the ground that Smith’s complaint failed to state a claim upon which relief could be granted. Smith appealed.