In Renk v. City of Pittsburgh, 537 Pa. 68, 641 A.2d 289 (1994), a police officer struck an individual during an arrest for disorderly conduct and detained him in a jail cell in the police station while the officer wrote the citation for the offense. The citation was dismissed when the officer failed to appear at a scheduled hearing. As a result, the individual brought suit, asserting a federal claim as well as state claims for assault, battery, false imprisonment and emotional distress. The jury found the officer liable on the state claims and awarded both compensatory and punitive damages. the officer subsequently filed suit seeking indemnification from the municipality. Our Supreme Court held: A police officer may be held liable for assault and battery when a jury determines that the force used in making an arrest is unnecessary or excessive, and for false imprisonment when a jury concludes that he did not have probable cause to make an arrest. It is conceivable that a jury could find a police officer liable for those torts under circumstances which demonstrate that the officer did not intentionally use unnecessary and excessive force, or did not deliberately arrest a person knowing that he lacked probable cause to do so. In this case, it is unclear whether the jury in the federal action determined that the officer intentionally used excessive force in effectuating the arrest, or only that he intentionally used force. Similarly, the jury's verdict does not resolve the issue of whether the officer intentionally effectuated the arrest knowing that he lacked probable cause to do so, or only that he lacked probable cause to make the arrest. The municipality relied solely upon the jury's verdict in the federal action and did not introduce any other evidence to support its claim that the officer's acts were willful misconduct. The jury verdict alone is insufficient to establish willful misconduct in this case. Nor is the award of punitive damages sufficient to establish willful misconduct, since reckless conduct may be sufficient to support such an award. Based upon the evidence of record, we find that the municipality failed to establish that the officer's acts were willful misconduct. Renk, 537 Pa. at 76-77, 641 A.2d at 293-94.