## Facts

- Marius S. Coblyn, a 70-year-old customer, shopped at a Boston department store to buy a sport coat and left it for alterations.
- Coblyn had an ascot he previously purchased elsewhere; after shopping, he put it around his neck near the store exit.
- As Coblyn stepped out, an employee stopped him, demanded to know where he got the scarf, grasped his arm, and told him to return to see the manager.
- Another employee stood by, and several onlookers watched, as Coblyn went back into the store.
- While being escorted upstairs, Coblyn experienced chest and back pains; a salesman confirmed the ascot was Coblyn’s, a nurse was summoned, and Coblyn was later hospitalized for a myocardial infarction attributed to the incident.
- A jury awarded Coblyn \$12,500 for false imprisonment.

## Issues

1. Whether the evidence permitted a finding that the store, through its employees, falsely imprisoned Coblyn.
2. Whether the detention was privileged under the shopkeeper detention statute requiring “reasonable grounds” and a reasonable manner and duration, and whether “reasonable grounds” is an objective probable-cause standard.

## Decision

- The Supreme Judicial Court of Massachusetts upheld the verdict for Coblyn and overruled the defendants’ exceptions.
- The evidence supported a finding of confinement because the employee’s command, physical grasp, and show of authority in a public setting reasonably compelled submission.
- The shopkeeper privilege did not apply because the employee lacked “reasonable grounds” (objective probable cause) to believe Coblyn was stealing store merchandise.
- The jury could also find the manner of detention unreasonable given the physical grabbing, public confrontation, and failure to proceed in a restrained, explanatory way.

## Legal Principles

- False imprisonment may be established by any restraint of personal liberty; physical force is unnecessary if a show of authority or physical power effectively compels submission.
- Restraint caused by fear of a personal difficulty may constitute confinement.
- Under the shopkeeper detention statute, “reasonable grounds” is equivalent to probable cause and is judged objectively by what a reasonably prudent person would believe under the circumstances.
- A merchant claiming statutory protection must show both objectively reasonable grounds and a detention conducted in a reasonable manner and for a reasonable time.

## Conclusion

The court affirmed liability for false imprisonment because the customer’s brief, public detention was compelled by an employee’s physical control and show of authority, and the statutory shopkeeper privilege failed where suspicion did not rise to objective probable cause and the detention’s manner could be found unreasonable.


Coblyn v. Kennedy's, Inc., 359 Mass. 319, 268 N.E.2d 860 (Mass. 1971)