Trammell v. Wright, 489 S.W.3d 636

Background

On May 14, 2012, Officer Travis Trammell (Bella Vista PD) arrested Linda Wright after ACIC records indicated an outstanding warrant in Washington County; Wright disputed the warrant at the scene.
The actual warrant available later named a different “Linda M. Wright” with different DOB, address, and driver’s license number; Trammell did not have or read the physical warrant at the scene and relied on ACIC and dispatch confirmation.
Wright was held in custody and later transferred to Washington County, where she bonded out; she was ultimately cleared because the warrant applied to a different person.
Wright sued Trammell in his personal capacity for false arrest/false imprisonment; Trammell moved for summary judgment based on immunity under A.C.A. § 21-9-301.
The circuit court denied summary judgment on immunity; the Court of Appeals dismissed an earlier appeal for lack of final order; this Court granted interlocutory review on the immunity/statutory-interpretation issue.
The Supreme Court majority held as a matter of law that Trammell did not commit intentional torts of false arrest/false imprisonment and reversed, granting summary judgment on immunity grounds.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Trammell committed the intentional torts of false arrest/false imprisonment	Wright: arrest and detention without a valid warrant; alleged wrongful arrest of wrong person supports intentional-tort claim	Trammell: relied on ACIC and dispatch confirmation; no intent to unlawfully arrest; no possession of warrant; facts undisputed	Court: as a matter of law, Trammell did not commit intentional false arrest/false imprisonment (no evidence of intent)
Whether A.C.A. § 21-9-301 immunizes Trammell from tort liability for negligence	Wright: claims are intentional torts, not negligence; immunity for negligence inapplicable	Trammell: to extent conduct was negligent, § 21-9-301 provides immunity; he also argued immunity should cover all torts (including intentional)	Court: resolved case on lack of intentional tort; did not decide whether § 21-9-301 covers intentional torts; recognized § 21-9-301 grants immunity for negligent acts but not intentional acts under existing precedent
Proper standard for immunity on facts of mistaken identity/warrant reliance	Wright: officer had no authority to arrest because warrant did not identify her; reliance on ACIC insufficient	Trammell: acting in good faith, followed protocol, sought dispatch confirmation; conduct was reasonable reliance entitled to immunity for negligent conduct	Court: factual record viewed as undisputed; held no intentional tort, implying officer’s conduct did not establish intentional misconduct; concurrence urged consideration of officer’s good-faith/reasonableness as basis for immunity
Reviewability of denial of summary judgment based on immunity	Wright: denial was correct; appellate review limited	Trammell: interlocutory appeal proper because denial of immunity defeats right to be free from suit; Court has jurisdiction	Court: exercised interlocutory jurisdiction and reviewed immunity de novo, reversed circuit court and remanded for entry consistent with opinion

Key Cases Cited

City of Fayetteville v. Romine, 373 Ark. 318 (reviewability of denial of immunity; de novo review)
Ark. River Educ. Servs. v. Modacure, 371 Ark. 466 (general rule on nonappealability of summary-judgment denials; immunity exception)
Smith v. Brt, 363 Ark. 126 (treating immunity as question of law; precedent on employee immunity)
Headrick v. Wal-Mart Stores, Inc., 293 Ark. 433 (equating false arrest and false imprisonment)
Grandjean v. Grandjean, 315 Ark. 620 (definition of false imprisonment)
Battle v. Harris, 298 Ark. 241 (intentional acts not covered by § 21-9-301 under prior cases)
Deitsch v. Tillery, 309 Ark. 401 (scope of immunity for public employees)
Felton v. Rebsamen Med. Ctr., 373 Ark. 472 (pleadings determine entitlement to immunity; standards for ruling on immunity at pleading stage)