P was a 67-year-old man who suffered from Parkinson's disease. He was admitted to a nursing home D by his nephew. The papers stated that P would not be kept in the nursing home against his will.
A few days after admission, P decided to leave. P was caught by employees of D and put in a wing for drug addicts and alcoholics (he was neither at the time). The wing was also used house uncontrollable patients.
P attempted to leave at least 6 more times and was caught every time. D prevented P from using a phone for 51 days and taped P to a chair to prevent him from leaving. D lost 30 pounds during his stay at the nursing home.
P sued D for false imprisonment.
Procedural History:
Lower court found for P, awarded actual and exemplary damages.
COA TX affirmed, found for P, awarded actual and exemplary damages, but in a reduced amount.
Issues:
Is a D liable for false imprisonment when the D has prevented the P from leaving a certain limited area without legal justification?
Holding/Rule:
A D is liable for false imprisonment when the D has prevented the P from leaving a certain limited area without legal justification.
A D is liable for punitive damages in addition to actual damages if they acted intentionally in depriving the P from his rights.
Reasoning:
False imprisonment…
Occurs where a party intends to confine another individual against his will.
In order for the individual to be confined, he must be within a definite physical boundary from where he is not free to leave.
There is plenty of evidence to show that P was falsely imprisoned in this case.
He was placed in a wing with drug addicts and alcoholics and did not belong there.
He was tied to a chair.
He was not allowed to use a telephone.
He repeatedly asked to be released and tried to escape.
Punitive damages are appropriate in this case since the D disregarded the P's rights intentionally.
Dissent:
None.
Notes:
If there is a reasonable means of escape of which the individual is aware, then there is no false imprisonment. Escape is unreasonable if it involves danger to the person, exposure of the person, material harm to the clothing, or danger of substantial harm to another.
The means of escape is not reasonable if P does not know of it, and it is not apparent.
There is no false imprisonment when an individual is prevented from entering an area or a building.
If the only means of escape could cause physical danger to P, and he could remain imprisoned without any risk of harm, P may not recover for injuries suffered in making his escape.
False imprisonment is an intentional tort. Negligence resulting in confinement will only lie if some actual damage occurred. In areas where intent is visible, no actual damage must be shown.
