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Eilers v. Coy - 582 F. Supp. 1093 (D. Minn. 1984)


False imprisonment consists of three elements:1) words or acts intended to confine a person; 2) actual confinement; and 3) awareness by the person that he or she is confined.


William Eilers and his pregnant wife Sandy were abducted from outside a clinic in Winona, Minnesota in the early afternoon of Monday, August 16, 1982, by their parents, relatives, and others hired by their parents. William was grabbed from behind by two or more security men, forced into a waiting van, and driven to the Tau Center in Winona, Minnesota. Forcibly resisting, he was carried by four men to a room on the top floor of the dormitory-style building. The windows of this room were boarded over with plywood, as were the windows in his bathroom and in the hallway of the floor. The telephone in the hallway had been dismantled. William  was held at the Tau Center for five and one-half days and subjected to the defendants' attempts to deprogram him. At the time of the abduction, William and Sandy were members of the religious group Disciples of the Lord Jesus Christ, which became a concern to his family because his personality changed substantially after he became a member of the group. William was able to escape from his abductors by jumping out of a moving van. William then filed a motion for a directed verdict against his abductors for falsely imprisoning him without legal justification and violating his civil rights during the deprogramming attempt. 


Was William entitled to a directed verdict on his claim alleging false imprisonment and violation of his civil rights?


Yes, in part.


The court granted William's motion for a directed verdict on the issue of false imprisonment and granted the motion for a directed verdict with respect to 42 U.S.C.S. § 1985(3) as to certain elements of plaintiff's claim that a conspiracy on the part of his relatives deprived him of certain of his federal constitutional rights. The court agreed holding that the evidence overwhelmingly established each of the elements of false imprisonment because 1) by their own admission, the relatives intended to confine the son for at least one week, 2) even if the parents' purpose was to help their son, William, it was not a defense, 3) there was no question that William was actually confined, and 4) the parents' failure to even attempt to use the lawful alternatives available to them was fatal to their assertion of the necessity defense. The court granted the son's motion in part and held that as a matter of law, William had established a conspiracy, an act in furtherance of the conspiracy, and injury or a deprivation of constitutional rights. However, it was for a jury to determine whether the purpose of the conspiracy was to deprive William of his civil rights.

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