not an element of a false arrest claim. See, e.g., Valenti v. Sheeler, 765 F.Supp. 227, 231 (E.D.Pa.1991) (two elements of false arrest/false imprisonment are (1) the detention of the person and (2) the unlawfulness of that detention); Renk v. City of Pittsburgh, 537 Pa. 68, 641 A.2d 289, 293 (1994) (same) (citing Fagan v. Pittsburgh Terminal Coal Corp., 299 Pa. 109, 149 A. 159 (1930)); Lokey v. Kinney, 57 Lanc.Rev. 491 (Pa. Comm.P1.1961) (same). Moreover, the cases cited in the state court decision primarily involved malicious prosecution claims. See Woodyatt v. Bank of Old York Road, 408 Pa. 257, 182 A.2d 500 (1962) (action for malicious prosecution); Sicola v. First Nat'l Bank of Altoona, 404 Pa. 18, 170 A.2d 584 (1961) (same). See also Smoker v. Ohl, 335 Pa. 270, 6 A.2d 810 (1939) (<HOLDING>). 9 . However, Plaintiff's § 1983 claims will
holding that a determination of probable cause does not bar a state law malicious prosecution claim where the claim is based on the police officers supplying false information to establish probable cause holding that only malicious prosecution requires a favorable termination of the criminal proceedings and that claims for intentional infliction of emotional distress and abuse of process accrue on the date of arrest holding that unappealed conviction gives rise to presumption of probable cause sufficient to defeat false arrestimprisonment claim and also noting that for malicious prosecution claims favorable termination of criminal proceedings is prerequisite to suit holding that the statute applies also to malicious prosecution actions recognizing that an arrest based on probable cause cannot be the basis of a claim for false arrestimprisonment