Sindle v. New York City Transit Authority

Brief Fact Summary.

Passengers on a school bus were boisterous and vandalized lights, windows, and ceiling panels. The bus driver informed the passengers that he intended to take them to the police station. The driver closed the bus doors and proceeded to the police station. One of the passengers sued for false imprisonment.

Synopsis of Rule of Law.

A person entrusted with the care or supervision of a minor may use reasonable force to maintain discipline or promote the welfare of the minor.

Facts.

Sindle was a fourteen-year-old student and passenger on the New York City Transit Authority’s bus, which was driven by the employee Mooney. The bus was filled with sixty-five to seventy other students. The passengers were in boisterous moods since it was the last day of school. Some of the passengers broke dome lights, windows, and ceiling panels on the bus. Mooney scolded the students about the noise and vandalism. During one stop, Mooney got up to inspect the damage. He then told the students that he was taking them to the police station. Mooney closed the bus doors and proceeded to the station, bypassing routine stops. Sindle and his father sued for false imprisonment.

Issue.

Should the trial court have admitted evidence of justification when a bus driver entrusted with the care of his student-passengers detained them en route to the police station?

Held.

Yes. It was an abuse of the trial court’s discretion to deny the motion to amend and exclude evidence of justification. The order of the appellate division is reversed and a new trial is granted.

Discussion.

Reasonable restraint or detention that is imposed for the purpose of either preventing another from inflicting injury or damaging personal property is not unlawful. Additionally, a person entrusted with the care or supervision of a minor may use reasonable force to maintain discipline or promote the welfare of the minor. Here, Mooney had the duty to take reasonable measures for the protection of both the students and the property of the New York City Transit Authority. The reasonableness of his actions as it pertains to his justification defense will be determined on remand.