In Renk v. City of Pittsburgh, 537 Pa. 68, 641 A.2d 289 (1994) a police officer responded to a request for assistance from a bus driver outside a police station and removed a passenger with an expired bus pass. As he took the passenger inside there was a scuffle and the officer's elbow struck the passenger's mouth. He was detained in a cell while the officer wrote the citation, which was dismissed when the officer failed to appear at the hearing. In the passenger's later federal court suit, the jury found in favor of the officer on a claim under 42 U.S.C. 1981, but it found the officer liable on state claims for assault, battery and false imprisonment and awarded compensatory damages of $ 2500 and punitive damages of $ 5000.