Whittaker v. Sanford

Brief Fact Summary.

The plaintiff was a member of the defendant’s religious sect, which had locations in Jaffa, Syria and Maine. The plaintiff tried to leave the sect and was imprisoned on a yacht docked in Maine.

Synopsis of Rule of Law.

False imprisonment requires some sort of physical restraint or barrier, not just a moral one.

Facts.

The plaintiff was a member of a religious sect that had colonies in Maine and Jaffa, Syria. The defendant was the leader of this religious sect. The plaintiff, while in Jaffa, announced her intention to leave the sect, and the defendant persuaded her to return to the United States on the sect’s palatial yacht, The Kingdom. The defendant promised the plaintiff that she and her children would be free to leave the ship at any time once they were in port. Once they docked in Maine, the defendant refused to allow the plaintiff to go ashore. The plaintiff eventually gained her release on a writ of habeas corpus. There was evidence that the plaintiff had been allowed to go ashore a number of times and that she had been treated as a guest on the yacht. No one ever physically restrained the plaintiff other than disallowing her from using the rowboats to get ashore.

Issue.

Is the defendant liable for the false imprisonment of the plaintiff?

Held.

Yes. The defendant is responsible, but the awarded damages are excessive.

Discussion.

The tort of false imprisonment requires that a victim be physically restrained, not restrained by mere moral pressure or influence. There must be some physical impediment, like a locked door or walls, to prove that one has been falsely imprisoned. In this case, the defendant did not allow the plaintiff to use the row boats, which is certainly a physical impediment. That being said, she was not closely confined, so the damages are excessive. This case lacks the elements of humiliation and disgrace that often accompany false imprisonment.