Adams v. Zayre Corp.

This suit was brought by a shopper for compensatory damages for false imprisonment. Defendant denied all material allegations and pleaded an affirmative defense of comparative negligence. The plaintiff, over defendant’s objection, was permitted to amend her complaint four days before trial to pray for punitive damages. A judgment for $2,500 in general damages, plus $30,000 in punitive damages was entered for plaintiff. A prompt post-trial motion was filed, argued and denied. This appeal timely followed.

On December 4, 1983, Mary Adams was detained by the security staff of the Zayre store in…