Steve Burditt v. Whataburger, Inc.
Steve Burditt appealed a summary judgment granted in favor of Whataburger, Inc., concerning claims of false imprisonment, negligence, and violation of the Texas Deceptive Trade Practices—Consumer Protection Act (DTPA). Burditt alleged he was detained by Whataburger staff after a $20 bill he used was suspected to be counterfeit, leading to his humiliation. The appellate court affirmed the trial court's decision on all counts. It found the shopkeeper's privilege justified the detention for false imprisonment. Furthermore, the court determined Burditt provided insufficient evidence of compensable mental anguish damages to support his negligence and DTPA claims, specifically lacking proof of "knowing conduct" required under the DTPA.