Cruz v. HomeBase

In Cruz v. HomeBase (2000) 83 Cal.App.4th 160, a store patron who had been detained on suspicion of shoplifting sued HomeBase, its security guard, and the security guard's supervisor for battery, false imprisonment, and malicious prosecution. (Id. at p. 163.) The supervisor participated in the acts giving rise to the causes of action, and the plaintiff sought to show the supervisor was a managing agent so as to impose punitive damages on HomeBase. (Id. at p. 166.) Rejecting this claim, the court explained as follows: "The supervisor was not a manager of numerous stores, but only a supervisor subordinate to the store manager in a single outlet of a multi-store chain. He supervised only a few employees, and had authority over only one narrow area of the single store's multifaceted operation: security. There was not a hint of evidence that he exercised authority over corporate principles or rules of general application in the corporation." (Id. at p. 168.)