Teel v. May Department Stores Co.

Teel (plaintiff) lived in St. Louis with her sister-in-law, Leona, who was in the process of divorcing Teel’s brother. Leona’s boyfriend was Mr. Foster. Mr. Foster told Leona that she could charge purchases to his account by saying that she was Mrs. Foster. Teel went shopping with Leona at a department store owned by May Department Stores Company (May Co.) (defendant). Leona made several large bedding purchases as Mrs. Foster, and Teel and Leona made multiple trips carrying the purchases to Leona’s car. Upon returning from the car to the bedding department for more parcels, May Co.’s detective, Zytowski, asked Teel and Leona to accompany him to the store’s credit department on the eighth floor. The store’s credit manager had already been in contact with the real Mrs. Foster and determined that no one else was authorized to make purchases on the Fosters’ account. The credit manager asked Leona if she was Mrs. Foster. Leona claimed she was, but the credit manager told her he knew she was not. Confronted with the fraud, Teel returned the merchandise that was in Leona’s car. Zytowski then refused to allow Teel and Leona to leave his office until they had each signed a confession. Teel sued May Co. for false arrest and imprisonment. The trial court instructed the jury that if it found there was any imprisonment greater than what was necessary to enable May Co. to recover its merchandise from Leona and Teel, then that imprisonment constituted false imprisonment. The jury found in favor of Teel, awarding her $1,000 damages. Teel appealed, alleging inadequate damages. May Co. also appealed, alleging that the trial court erred by not issuing a directed verdict and by instructing the jury improperly in regard to false imprisonment.