Whittaker v. Sanford

85 A. 399 (Me. 1912)

A seminal case on the intentional tort of false imprisonment.

Defendant was a leader of a religious sect to which Plaintiff belonged as a member.  After Plaintiff expressed her desire to leave the sect, Defendant offered to Plaintiff and her children passage aboard his yacht and, in response to her expressed concerns that she would be held captive until “won back to the movement,” Defendant promised that she would be allowed to leave the yacht once it reached America and would not be detained on board.

When the yacht reached Maine’s harbors, however, Defendant refused to provide Plaintiff with a boat so that she could leave the yacht (except for several shore visits, which were always in her husband’s company).  She eventually secured liberty for herself and her children through a writ of habeas corpus.

In her legal action, the trial court instructed the jury to the effect that false imprisonment, while requiring physical restraint (such as being locked in a room) rather than mere moral influence, does not require actual application of force to plaintiff’s person; and that Defendant’s refusal to supply Plaintiff with the means to leave the yacht (i.e., a rowboat) amounted to a physical restraint.  The jury rendered a verdict for Plaintiff.

In upholding the trial court’s jury instructions, Maine’s Supreme Judicial Court reasoned that the sea surrounding a vessel at anchor was like the four walls of a room, and that Defendant’s refusal to provide Plaintiff a boat with which to reach the shore was like turning a key in the lock on the door.  Even if one voluntary enters a room, as Plaintiff voluntarily entered the yacht, it is false imprisonment to lock the door.