Wednesday, January 1, 2014

Whittaker v. Sandford case brief

Whittaker v. Sandford case brief summary
85 A. 399 (1912)

Defendant leader appealed from the judgment of the trial court (Maine) that held in favor of plaintiff member in the member's action for false imprisonment.

The member was affiliated with a religious sect headed by the leader. The sect owned two yachts that were used to transport members between the United States and Syria. The member traveled to Syria on one of the yachts but later determined to leave the sect and return to the United States. After a returning yacht reached the United States, the member was refused use of the rowboats needed to reach shore despite numerous requests. She remained on the yacht for almost a month until she obtained her liberty through the issuance of a writ of habeas corpus.

A jury concluded that the leader had falsely imprisoned the member and awarded her damages.


  • In affirming that judgment, the court held that the trial court properly admitted evidence of the leader's influence over the other members as it was relevant to show that, even though he was not aboard the yacht, he controlled the use of the rowboats and used his influence to prevent the member from leaving. 
  • The amount of the award was reduced by the court, however, because the member had been treated well during the ordeal.

The court affirmed the judgment in favor of the member in her false imprisonment action against the leader; however, it ordered a reduction in the amount of the verdict awarded.

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