Lawson, K. v. Albert Einstein Medical Center

CourtSuperior Court of Pennsylvania
DecidedDecember 2, 2020
Docket889 EDA 2019
StatusUnpublished

This text of Lawson, K. v. Albert Einstein Medical Center (Lawson, K. v. Albert Einstein Medical Center) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lawson, K. v. Albert Einstein Medical Center, (Pa. Ct. App. 2020).

Opinion

J-A23022-20

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

KEENAN AND SHADE LAWSON, H/W : IN THE SUPERIOR COURT OF : PENNSYLVANIA Appellants : : : v. : : : ALBERT EINSTEIN MEDICAL CENTER : No. 889 EDA 2019

Appeal from the Judgment Entered October 3, 2018 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 3214 June Term 2016

BEFORE: BENDER, P.J.E., KUNSELMAN, J., and PELLEGRINI, J.*

MEMORANDUM BY PELLEGRINI, J.: FILED DECEMBER 02, 2020

Keenan (Lawson) and Shade Lawson, h/w (collectively, the Lawsons)

appeal nunc pro tunc from the judgment entered on October 3, 2019, in favor

of Albert Einstein Medical Center (Einstein) in the Court of Common Pleas of

Philadelphia County (trial court). Specifically, the Lawsons argue that the trial

court erred in giving a misleading non-standard citizen’s arrest jury

instruction.

This contention is perplexing because Lawson did not plead there was

false imprisonment, an illegal detention or an illegal citizen’s arrest and

____________________________________________

* Retired Senior Judge assigned to the Superior Court. J-A23022-20

Einstein did not plead that there was a proper citizen’s arrest as a defense.1

Nonetheless, both the Lawsons and Einstein and the trial court focus on the

1 “The concept of citizen’s arrest as it has been developed by the courts is almost exclusively used as defense or justification on the part of the arresting person. In tort law the citizen’s arrest is defined as a privilege that prevents an intentional invasion of another person’s interests, which otherwise would constitute assault, battery, and false imprisonment, from being tortious and, therefore, the basis for civil liability. The conditions required to establish the privilege, generally stated, are that a felony has been committed and that the actor reasonably suspects that the person whom he arrests has committed the felony. See Mahaffey v. Byers, 25 A. 93 (Pa. 1892); see generally Restatement (Second) of Torts, §§ 118, 119, 127.” Commonwealth v. Corley, 491 A.2d 829, 833–34 (Pa. 1985).

Section 118 of the Restatement (Second) provides that “a private person is privileged to arrest another without a warrant for a criminal offense

(a) if the other has committed the felony for which he is arrested, or

(b) if an act or omission constituting a felony has been committed and the actor reasonably suspects that the other has committed such act or omission, or

(c) if the other, in the presence of the actor, is committing a breach of the peace or, having so committed a breach of the peace, he is reasonably believed by the actor to be about to renew it, or

(d) if the other has attempted to commit a felony in the actor’s presence and the arrest is made at once or upon fresh pursuit, or

(e) if the other knowingly causes the actor to believe that facts exist which would create in him a privilege to arrest under the statement in Clauses (a) to (d).

Our Supreme Court expressly declined to reach “the propriety of the Superior Court’s holding that a citizen may arrest for a misdemeanor breach of the peace committed in his presence.” Commonwealth v. Corley, 491 A.2d

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propriety of a citizen’s arrest, even though they differ on when the citizen’s

arrest occurred and for what offense he was arrested.

Nonetheless, for the reasons that follow, we affirm.

I.

We take the following factual background and procedural history from

the trial court’s April 11, 2019 opinion and our independent review of the

certified record.

On June 28, 2016, the Lawsons filed a civil personal injury complaint

against Einstein for assault and battery, intentional infliction of emotional

distress and loss of consortium related to an incident that occurred at

approximately 3:00 A.M. on the morning of July 1, 2014. The Complaint

alleged Lawson picked up a husband and wife and transported the husband to

the hospital because he was shot. After Einstein Security Officers secured the

car and Lawson exited (First Interaction), the Complaint alleged:

7. Upon [Lawson’s] arrival at the front entrance of the emergency room, the woman [(wife)], who was assisting the wounded man [(husband)] inside, requested that Plaintiff Keenan Lawson hold a few items while she assisted him into the hospital.

8. Plaintiff Keenan Lawson noticed that one of the items was a bag which appeared to contain a small amount of marijuana and he indicated to the woman that “she couldn’t take that into the hospital with her.”

829, 834 (Pa. 1985). We note that Corley was a suppression case and a citizen’s arrest was not being used as a defense to a civil claim.

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9. While Plaintiff Keenan Lawson was holding the items, an Albert Einstein security guard stated that “you better get rid of that before the police arrive.”

10. Plaintiff Keenan Lawson walked a few steps to throw the bag into a nearby trash can when suddenly and without warning, he was attacked by about five (5) Albert Einstein security guards, one of whom stated “oh, so now you are trying to run.

11. At that juncture, Plaintiff Keenan Lawson, in the presence of his wife, Shade Lawson, was handcuffed by these security guards and then brutally beaten despite the fact that Plaintiff Keenan Lawson offered no resistance whatsoever [(Second Interaction)].

(Complaint, 6/28/16, at 2) (pagination provided).

Einstein filed an Answer with New Matter on September 7, 2016, in

which it stated, in relevant part, that it did not “wrongfully, maliciously,

intentionally, or without cause illegally or wantonly assault [Lawson].”

(Answer with New Matter, 9/07/16, at Paragraph 34). It did not raise a

citizen’s arrest defense. At trial, the following pertinent facts were adduced.

A.

1.

Lawson testified that at approximately 3:00 A.M. on the morning of July

1, 2014, he woke up hungry and went to a local Chinese restaurant where a

woman, Monique Taylor, asked him if he would give her a ride home. (See

N.T. Trial, 3/29/18 (Volume 1), at 69-70). As the two drove on Germantown

Pike in Philadelphia, a man bleeding from a gunshot wound and his wife

flagged down Lawson because they had just been robbed and needed a ride

to the emergency room. (See id. at 70-71). The two individuals got in the

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back seat of Lawson’s vehicle and he took them to Einstein. (See id. at 72-

73). The gunshot victim went into the hospital and his wife stayed behind to

give Lawson some marijuana in her possession so she would not be caught

with it in the hospital. (See id. at 73-74). He testified that without providing

him any reason, the Einstein security guards immediately told him to give

them the keys to his car and that he and Taylor had to vacate the vehicle.

(See id. at 74-76). Lawson immediately got out of the car, gave the security

guards his keys and walked away to call his mother. (See id. at 74, 76).

While on the phone, several security guards rushed him, threw him to the

ground, punched and kicked him and started searching his pockets. (See id.

at 76-77). Lawson testified that he immediately told the officers he was

licensed to carry a firearm. (See id. at 77).

2.

Einstein Security Officer Wesley Applegate testified to slightly different

facts. During his testimony, he explained to the jury what was occurring on

an Einstein security tape of the incident and his motivations for the actions

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Bluebook (online)
Lawson, K. v. Albert Einstein Medical Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawson-k-v-albert-einstein-medical-center-pasuperct-2020.