Jurisprudence on Reasonable Force and Unnecessary Indignities

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The manner is unreasonable when the suspect is “subjected to gratuitous and unnecessary indignities.” Wolter v. Wal-Mart Stores, 559 S.E.2d 483, 486 ( Ga. Ct. App. 2002). Embarrassment and accusations that are “abusive, opprobrious, insulting, or slanderous” are considered “gratuitous and unnecessary indignities.” Wolter, 559 S.E.2d 483, 486; Swift v. Kresge Co., 284 S.E.2d 74 ( Ga. Ct. App. 1981). Additionally, force is reasonable if it is necessary, “non-confrontational,” and not in conflict with other testimony. Brown v. Super Disc, 477 S.E.2d 839, 841 (Ga. Ct. App. 1996); Wal-Mart Stores v. Johnson, 547 S.E.2d 320 (Ga. Ct. App.2001). The time is reasonable when it is used to investigate the innocence of the accused and less than forty-five minutes. Colonial Stores v. Fishel, 288 S.E.2d 21, 23 ( Ga. Ct. App. 1981); Dixon v. S. S. Kresge, Inc, 169 S.E.2d 189 ( Ga. Ct. App. 1969).
Embarrassment and words spoken as a result of a reasonable suspicion are not “gratuitous and unnecessary indignities.” Wolter, 559 …show more content…

Fishel, 288 S.E.2d at 21; Dixon, 169 S.E.2d at 189. In Fishel, the customer was detained on the suspicion of shoplifting aspirin. 288 S.E.2d at 21. While he was detained the manager handcuffed him to the chair and made no attempt to investigate. Id. at 23. The manager's actions were not covered under the shopkeeper’s privilege because of the manager’s failure to reasonably investigate the customer's claims of innocence. Id. at 23. Conversely, in Dixon, the customer was detained on the suspicion of shoplifting for about forty-five minutes while the store’s employees investigated. 169 S.E.2d at 189. The employee’s had reasonable suspicion that the customer was attempting to shoplift a hat, when the employee saw the customer's friend remove the tag. Id. The appeals court ruled in favor of the store since the actions were a result of the reasonable suspicion. Id. at

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