Sims v. Geohagan

KENNEDY, Justice.

The plaintiff, Oscar Sims, appeals from the dismissal of his action against the defendant, Steve Geohagan.

Geohagan, a City of Florala police officer, detained Sims on December 1, 1986. Sims alleged that Geohagan “unlawfully arrested and imprisoned [Sims] in the Florala city jail for a period of 12 hours.” Sims sued on a theory of false imprisonment.1

Before he filed this action, Sims had sued Geohagan in a federal court, claiming damages pursuant to 42 U.S.C. § 1983, for an alleged violation of his civil rights; that federal action related to the same incident that gave rise…