## Facts

- Ifeanyi Oramulu worked for Washington Mutual Bank in Houston as a personal financial representative and later as a senior personal financial representative.
- Washington Mutual believed Oramulu was connected to missing customer funds and treated the matter as an internal fraud investigation.
- Two bank employees, including Griggs and Moreau, questioned Oramulu in an interview that lasted more than eight hours.
- Oramulu alleged the investigators used intimidation, including telling him the police were on the way and that he would go to prison where he would be raped.
- Oramulu claimed the threats overcame his ability to leave and that, in practical terms, he was not free to end the interview and walk out.
- Oramulu sued Washington Mutual. Among other theories, he asserted a Texas false-imprisonment claim based on the interrogation.
- Washington Mutual moved for summary judgment and also moved to strike portions of Oramulu’s summary-judgment evidence.

## Issues

1. Whether Washington Mutual was entitled to summary judgment on Oramulu’s Texas false-imprisonment claim where Oramulu alleged an hours-long interrogation accompanied by threats of police involvement and prison rape.
2. Whether Oramulu’s employment-discrimination theories (asserted under federal law) could survive summary judgment on the record presented.
3. Whether Oramulu’s defamation and negligence-based workplace tort theories were barred or unsupported as a matter of Texas law at the summary-judgment stage.
4. Whether the court should strike identified portions of Oramulu’s summary-judgment materials as inadmissible (for example, hearsay or lack of authentication).

## Decision

- The court granted in part and denied in part the bank’s motion to strike, excluding summary-judgment material that did not satisfy Rule 56 evidentiary standards.
- The court granted in part and denied in part the bank’s motion for summary judgment.
- On false imprisonment, the court denied summary judgment, holding that Oramulu’s evidence—viewed in the light most favorable to him—raised a triable fact question as to whether he was restrained by intimidation and threats such that a reasonable person would not have felt free to leave.
- The court granted summary judgment against Oramulu on certain other claims and theories addressed in the motion, including parts of his employment-related claims that lacked sufficient admissible proof to proceed.

## Legal Principles

- Summary judgment requires the nonmovant to point to evidence that would be admissible at trial (or capable of being presented in admissible form); courts may strike materials that are inadmissible, unauthenticated, or conclusory.
- Under Texas law, false imprisonment requires a willful detention of a person, without consent, and without authority of law.
- “Detention” can be shown not only by physical force or locked doors, but also by threats or intimidation that would cause a reasonable person to believe he was not free to leave.
- At summary judgment, the court does not decide whose account is true; it asks whether the evidence creates a genuine dispute of material fact for a jury, and it must draw reasonable inferences in favor of the nonmovant.

## Conclusion

The district court’s order resolved competing Rule 56 and evidentiary motions arising from Washington Mutual’s fraud investigation interview of Oramulu: it narrowed the case through partial summary judgment and evidentiary exclusions, but it allowed the false-imprisonment claim to proceed because the alleged eight-hour interrogation and severe threats created a jury question on whether Oramulu was restrained against his will.


Oramulu v. Washington Mutual Bank, 699 F. Supp. 2d 898 (2009)