It was the last day of school, and the students started vandalizing the bus. P was probably not involved in the vandalism.
The bus driver informed the students that he was going directly to the police station, thereby passing P's stop.
P sued the NYC Transit Authority (D) for false imprisonment.
Procedural History
Trial court found for P, denying the motion of D to amend their answer to include the defense of justification.
Ct of Appeals reversed and remanded for new trial.
Issues
Is restraint or detention which is reasonable under the circumstances, imposed for the purpose of preventing another from inflicting personal injuries or property damage, unlawful?
Holding/Rule
Restraint or detention which is reasonable under the circumstances and is imposed for the purpose of preventing another from inflicting personal injuries or property damage is not unlawful.
Reasoning
The trial court abused its discretion in denying the D its motion to bring evidence of justification.
A school bus driver entrusted with the care of his student passengers and the custody of public property (bus) has the duty to take reasonable measures for the safety and protection of both.
Therefore, the reasonableness of the driver's actions should have been determined.
Dissent
None.
Notes
Justification can be used as a defense when a D's conduct does not fall squarely within any other defense.
Justification looks at the circumstances surrounding the D's conduct to determine whether the D acted reasonably.
It also looks at D's position of authority and the alternatives the D had.
