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The tort of false imprisonment protects an interest which is in large part a mental or emotional one. See, e.g., W. PAGE KEETON ET AL., PROSSER AND KEETON ON THE LAW OF TORTS § 11, at 47 (5th ed. 1984) ('the interest is in a sense a mental one'). For an action of false imprisonment, 'mental pain and suffering, and the indignity and humiliation inflicted upon the plaintiff constitute just basis for compensatory damages.' W. T. Grant Co. v. Owens, 149 Va. 906, 141 S.E. 860, 866 (Va. 1928); S.H. Kress & Co. v. Roberts, 143 Va. 71, 129 S.E. 244, 245 (Va. 1925) (citing Bolton v. Vellines, 94 Va. 393, 26 S.E. 847, 850 (Va. 1897) ('compensatory damages may be had 'for the loss of time; [and] for the suffering, bodily and mental, sustained by reason of such wrongful acts or act')). Federal and state courts applying the law of the Commonwealth of Virginia have held that the personal injuries governed by § 8.01-243(A) include causes of action for infliction of emotional distress. E.g., Welch v. Kennedy Piggly Wiggly Stores, Inc., 63 Bankr. 888, 898 (Bankr. W.D. Va. 1986); Moore v. Allied Chemical Corp., 480 F. ...
