## Facts

- Gary Donroe, while emotionally disturbed, shot himself in the shoulder at a package store in West Haven, Connecticut.
- Donroe called police and knowingly made a false robbery report, describing an assailant as a Black male wearing a green jacket and blue hat, with additional general physical characteristics.
- Police encountered John Green, a Black man wearing a green jacket, detained him, and transported him to Donroe for identification.
- Donroe did not identify Green as the assailant, and Green was released after about ten minutes in police custody; Green suffered no further harm from the incident.
- Donroe later admitted the report was a hoax and was arrested and prosecuted for giving false information to police.
- Green sued Donroe and others asserting (1) false imprisonment and (2) a civil-rights violation; after a bench trial, judgment entered for defendants on both counts, and Green appealed.

## Issues

1. Whether a private individual is liable for false imprisonment when he knowingly gives false information to police that results in another person’s brief detention, absent intent to confine that person or “instigation” of the detention.
2. Whether a private individual’s false report to police constitutes state action (or action under color of law) sufficient to support a civil-rights claim.

## Decision

- The Connecticut Supreme Court affirmed judgment for the defendants on both counts.
- The court held Donroe was not liable for false imprisonment because he did not instigate or procure Green’s detention within the meaning of governing tort principles.
- The court held the civil-rights claim failed because Donroe was a private actor and the required element of state action was not shown.

## Legal Principles

- False imprisonment is the unlawful restraint of another’s physical liberty; even a brief restraint can support liability.
- A private person may be liable for false imprisonment if he instigates or procures an unlawful arrest or detention, such as by directing or insisting that police take a particular person into custody.
- Merely furnishing information to law enforcement, even if knowingly false, does not by itself establish false-imprisonment liability when police make an independent judgment to detain someone.
- A civil-rights claim premised on constitutional violations generally requires action under color of law; a private individual does not become a state actor solely by reporting (or misreporting) a crime absent significant joint participation with the state.

## Conclusion

The court held that Donroe’s knowingly false report was wrongful but did not create tort liability for Green’s brief detention because the police independently selected and detained Green, and Donroe neither identified Green nor instigated his confinement; the related civil-rights claim also failed for lack of state action.


Green v. Donroe, 440 A.2d 973 (Conn. 1982)