Las Vegas partner Michael Lowry and associate Jonathan Pattillo were granted summary judgment for the firm’s department store retail chain client in United States District Court, District of Nevada. The plaintiff alleged that the store had cooperated with police and other stores in an investigation of an organized retail theft group, which violated his civil rights under color of state law per 42 USC 1983, defamed him by identifying him as being involved in the crime and resulted in his false imprisonment. The charges stemming from the investigation were dropped when the plaintiff noted he was incarcerated for unrelated convictions when the retail thefts occurred. Michael and Jonathan argued that someone who is already incarcerated cannot be falsely imprisoned by someone else and that there were no strong indicators of a conspiracy present. In granting summary judgment to the firm’s client, the judge also concluded there is a limited privilege to defame for people reporting crimes and cooperating with police. The limits of that privilege were not breached here.