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A temporary interference with a plaintiff's legal right of egress can be justified as a proper police measure if the plaintiff sought to exercise such right under circumstances likely to create disorder and danger.
Plaintiff buyer went into the enclosure of the stadium to purchase seats for a baseball game, but the tickets had all been sold. He tried to leave the enclosure through some gates used generally for ingress and exit. The plaintiff was prevented by the stadium owner's servants from attempting to pass out through the throng of people. The plaintiff was detained in the enclosure for an hour or more. He was then taken through a club house within the enclosure and allowed to go out through the entrance to the club house to the street. Plaintiff instituted an action for false imprisonment against the defendant. The jury found that the plaintiff’s detention was unjustifiable under the circumstances, and the trial court entered judgment in favor of the plaintiff. The defendant challenged the decision.
Was the plaintiff’s detention justifiable under the circumstances?
The court affirmed the decision. The buyer had a legal right to leave the enclosure. A temporary interference with the buyer's legal right of egress could have been justified as a proper police measure if he sought to exercise such right under circumstances likely to create disorder and danger. Assuming, however, that the stadium owner was justified in preventing the buyer from passing out through the gates, it should have directed him to pass out through some other means of exit, if there were any. Thus, the court saw no reason to interfere with the verdict of the jury in its finding that the buyer's detention was unjustifiable. The sum awarded was not excessive.