Supreme Court of Arkansas

Travis Trammell, Appellant v. Linda Marlene Wright, Appellee

April 7, 20162016 Ark. LEXIS 126

Summary

The court held that the officer was entitled to summary judgment because the undisputed evidence did not establish that he committed the intentional torts of false arrest or false imprisonment when he relied on matching identification information in the state database and confirmed the warrant with dispatch. Because the plaintiff alleged only intentional torts, the court did not decide whether the governmental-immunity statute extends to intentional tort claims. The order denying immunity-based summary judgment was reversed and remanded. Special Justice Gardner concurred in the result but advocated a good-faith and reasonableness approach to immunity, while Justice Hart, joined by Justice Baker, would have affirmed because the complaint sufficiently alleged false imprisonment and the majority improperly resolved the merits.