Hughes

I. BACKGROUND

Hughes went to Target in October 2015. The details of her visit are disputed, but the parties agree that she interacted with Eric Santiago, a uniformed entry-level Target security guard who accused her of having made a fraudulent return of merchandise on a prior visit, and Chris Beagle, an assistant manager who was summoned to intercede.

1 Undesignated statutory references are to the Code of Civil Procedure. Hughes sued Target in October 2017, alleging that Target’s security confronted her without probable cause and that management endorsed the conduct. A. The Operative Complaint and Pretrial Proceedings

In her operative third amended complaint, Hughes pleaded three causes of action: (1) general negligence; (2) intentional infliction of emotional distress; and (3) violation of the Unruh Civil Rights Act (Civ. Code, § 51 et seq.). In support, Hughes alleged that she entered a Target store carrying a small purse and intending only to develop photos. After using a self-service machine but before paying at the customer service checkout, Hughes was confronted by a uniformed Target security guard who accused her of trespassing. At Hughes’s request, a Target…