Whitaker v. Sanford

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Whitaker v. Sanford, 10 Me. 77, 85 A. 399 (1912)

Plaintiff was part of a religious sect that had colonies in Maine and Jaffa, Syria and the defendant was the leader of this religious sect. While in Jaffa, plaintiff revealed that she was planning to leave the religious sect. The defendant and the plaintiff’s husband convinced the plaintiff to travel back to the U.S. in the religious sect’s yacht. The plaintiff was informed that she will be free to leave after the yacht reaches Maine. The yacht reached Maine and the plaintiff requested that a boat should be provided to her so she and her children can reach to shore. The defendant refused to provide the boat. No physical force was used against the plaintiff to force her to stay abroad the yacht but at the same time, the means of her leaving were also not provided.

Plaintiff sued the defendant for false imprisonment and the jury awarded plaintiff the sum of $1100.

The issue facing the appellate court was whether the trial court erred by instructing the jury that the plaintiff need not be physically forced to stay on the boat in order for her to establish false imprisonment. The court held that the trail court did NOT err.

The court held that for false imprisonment, physical force is not required. For instance, if a person intentionally turns the key and locks a person in a room, false imprisonment has taken place. Similarly, in the current case, the defendant refused to provide the plaintiff with the means of reaching the shore which he promise he would after they reach their destination. So the plaintiff was actually imprisoned by the walls of water and the defendant refused to provide the key. But the court also noted that a verdict in the amount of $1100 was excessive in light of all the evidence.