P was a member of a religious sect of which D was the leader. P decided to leave the sect.
The sect was quartered in Jaffa, Tel Aviv. D offered P his boat so that P could come back to the US. Upon arrival at the US, D refused to provide P with any means of getting to shore.
P was detained on the boat for about a month.
P sued D for false imprisonment.
The trial court instructed the jury that the P must show actual physical restraint; however, however, there need not be actual physical force upon the P herself.
Since P was restrained such that she could not leave the boat, the requirement of physical restraint was satisfied.
Procedural History:
Trial court found for P, dismissed D's motion for new trial.
ME affirmed, found for P.
Issues:
Can confinement of an individual to a bounded area, without means of egress, result in false imprisonment even if there is no actual physical restraint used upon the individual?
Holding/Rule:
Confinement of an individual to a bounded area, without means of egress, can result in false imprisonment even if there is no actual physical restraint used upon the individual.
Reasoning:
D assured P that she could leave the boat. D did not provide her with a rowboat. Thus, P was locked in the boat just as if she were locked in a room.
D's duty was to get P to the US and to furnish means of getting her to the shore.
Failure to provide a means of egress, when there is an obligation to do so, could constitute the physical barrier requirement for false imprisonment. Thus, it is not the act that resulted in false imprisonment, but his failure to release the P when there was a duty to do so.
