Sindle v. New York Transit Authority

Brief Fact Summary. Plaintiff was a passenger on a school bus owned by Defendant transit authority and driven by Defendant Mooney. Students aboard the bus were behaving rather disobediently and causing damage to the bus despite Defendant’s admonitions. Ultimately, Defendant bypassed the usual stops and took the Plaintiff and a few other students to a police station.

Synopsis of Rule of Law. Reasonable restraint or detention undertaken with the aim of preventing another from inflicting personal injury or damaging property is not unlawful.

Facts. Plaintiff was a student and passenger aboard a school bus owned by the transit authority and driven by Defendant. Several of the students aboard the bus were engaged in raucous behavior and caused damage to the bus. Defendant repeatedly told them to behave, but to no avail. Finally, after he had inspected the damage, Defendant informed the students that he was taking them to the police. He stopped making the usual stops and delivered the students to the police. Plaintiff sued for false imprisonment. At trial, Defendant argued his actions were justified, but the trial court excluded evidence of justification. Judgment was entered for Plaintiff and the Appellate Division affirmed and Defendants timely appealed.

Issue. Did the trial court abuse its discretion in excluding the evidence of justification proffered by Defendants?

Held. Yes. The judgment was reversed and remanded for a new trial.
* One is justified in restraining or detaining another in a manner reasonable under the circumstances to prevent personal injury or damage to property, and evidence regarding such justification should not have been excluded in evaluating this claim of false imprisonment.
* A parent, guardian, or teacher entrusted with care of a child is justified in using that physical force reasonably necessary for discipline or the child’s own welfare.
* It is the Defendant’s burden to plead and prove justification.

Discussion. The Court introduces the defense of justification for the use of physical force. In finding justification, the Court focuses upon the bus driver’s role as the supervisor of the students on the bus, creating a special relationship between the parties. The Court also notes that the burden is on the Defendant to prove justifice.