Maniaci v. Marquette University

Brief Fact Summary.

Manaici filed suit for false imprisonment against Marquette University after the Dean of Women had Maniaci institutionalized when they were unsuccessful in keeping Manaici from withdrawing from the university.

Synopsis of Rule of Law.

A defendant is liable for abuse of process if the defendant uses legal process to serve a defendant for any purpose other than what the process is meant for.

Facts.

Maniaci, a freshman at Marquette University, did not like college, bought a train ticket, and began to pack. The Dean of Women was unsuccessful in convincing Maniaci to remain at the school. When they were unable to reach Maniaci’s father, the doctor of the college had Maniaci institutionalized. Maniaci was released from the hospital when her father was reached. Manaici filed suit for false imprisonment against Marquette University after the Dean of Women had Maniaci institutionalized when they were unsuccessful in keeping Manaici from withdrawing from the university. The trial court granted judgment to Maniaci.

Issue.

Whether a defendant is liable for abuse of process if the defendant uses legal process to serve a defendant for any purpose other than what the process is meant for?

Held.

Yes. The judgment of the trial court is reversed. The confinement was lawful and did not constitute false imprisonment because the Deans followed the rules prescribed by the state. Maniaci may be able to plead a claim of abuse of process because the defendants followed Wisconsin law to place Maniaci in the hospital, but they did not institutionalize Maniaci out of concern for her mental health.

Discussion.

A defendant is liable for abuse of process if the defendant uses legal process to serve a defendant for any purpose other than what the process is meant for. Abuse of process includes using legal procedures to obtain an ulterior motive hat the process was not designed for.