Brief Fact Summary. Plaintiff, a retiree, was checked into Defendant’s nursing home at the behest of his nephew. Upon checking in, the admission papers indicated that Plaintiff’s presence was strictly voluntary and he could leave at any time. However, when Plaintiff attempted to leave on numerous occasions, he was restrained, punished, denied privileges, and moved to a wing of the home for drug addicts and the insane.
Synopsis of Rule of Law. False imprisonment is one person’s direct restraint of another’s physical liberty in the absence of sufficient legal justification.
Issue. Was the jury wrong to find Plaintiff had been falsely imprisoned?
* Was the award of punitive damages improper under these circumstances?
Held. The jury’s verdict was upheld, except the award was found excessive. Plaintiff accepted the remittitur proposed by the court of appeals.
* When a nursing home detains a retiree against his will despite an agreement that his presence is voluntary and has no other legal justification for the physical detention, it has committed false imprisonment.
* When a Defendant’s acts giving rise to actual damages are undertaken wrongfully, intentionally, and without regard to the rights of the Plaintiff, punitive damages may be appropriately awarded.
Discussion. This is a rather straightforward false imprisonment case. Plaintiff was even able to identify a contractual provision specifically demonstrating the Defendant’s knowledge that it acted in disregard of his rights. The relative simplicity of the case allows the Court to set forth the precise elements of the tort of false imprisonment.