K-Mart Corp. Store No. 7441 v. Trotti
This case involves an appeal by K-Mart Corporation against a judgment awarding an employee, Billie Trotti, damages for invasion of privacy. Trotti's personal locker, secured with her own lock, was searched by K-Mart management due to suspicion of theft by an unidentified employee. The appellate court reversed and remanded the case for a new trial, citing errors in the trial court's jury instructions regarding the definition of "invasion of privacy" and "mental anguish." Specifically, the lower court failed to include the "highly offensive to a reasonable person" standard for invasion of privacy and improperly allowed "mere embarrassment" as a separate element for damages. However, the court affirmed the jury's findings of invasion of privacy and malice, emphasizing that an employee's use of a personal lock creates a legitimate expectation of privacy.