In Alvarado v. City of Dodge City, 238 Kan. 48, 708 P.2d 174 (1985), the court addressed a 1983 claim against an off-duty police officer for his actions as a store security guard in apprehending the plaintiff as a suspected shoplifter. The Alvarado court recognized that where a deprivation of life, liberty, or property is "caused by a random and unauthorized state act for which prior process is impracticable or impossible," a postdeprivation remedy is the avenue for redress and a 1983 claim does not lie. 238 Kan. at 54. Alvarado held that under the facts of that case, "the Kansas tort actions for false imprisonment, battery, and defamation provide an adequate postdeprivation remedy sufficient to satisfy the requirements of due process under the Fourteenth Amendment." Alvarado, 238 Kan. at 55. The Supreme Court held that an off-duty police officer, working as a private security guard, acted under color of state law when he detained plaintiff as a suspected shoplifter, displayed his badge, and told her that she was under arrest.