Does the difference in name between false arrest and false imprisonment matter?

"New York", United States of America

The following excerpt is from Sbrigato v. JC Penny Corp., 2012 N.Y. Slip Op. 51140, 36 Misc.3d 1201, 954 N.Y.S.2d 761 (N.Y. Sup. Ct. 2012):

1. Regardless of plaintiff's arguments that her claims are for false imprisonment rather than false arrest, the difference in name makes no legal difference as false arrest and false imprisonment are two names for the same tort ( see Holland v. City of Poughkeepsie, 90 AD3d 841, 844845 [2011] ).

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