144 A.D. 337 (N.Y. App. Div. 1911).
Plaintiff went to the ballpark to buy a ticket. He entered an enclosure within the park where there were ticket booths. After finding out that the game was sold out, Plaintiff attempted to leave the park through the enclosure’s ingress and egress gates. However, the game was of such intense interest to the fans that they arrived early at the park, literally by the thousands.
Apparently because of the flow of the arriving crowd through the gates to the enclosure, the ballpark police restrained plaintiff and others from leaving the park through those gates and failed to show them alternate means of leaving. After more than an hour of being forced to remain in the ballpark, Plaintiff was led through the clubhouse and out to the street through the clubhouse door.
Plaintiff sued for false imprisonment.
The court ruled that although Defendant’s agents may have been justified in preventing Plaintiff and others from exiting through the entrance gates to suppress disorder and danger, Defendant owed the Plaintiff an active duty to point out other means of egress, and Defendant’s failure to do so made it guilty of false imprisonment.