Lexplug logoLexplug

Eilers v. Coy

United States District Court, D. Minnesota, Fourth Division
582 F. Supp. 1093 (1984)
ELI5:

Rule of Law:

The common law defense of necessity does not justify the false imprisonment of an adult for deprogramming purposes when lawful alternatives, such as statutory civil commitment procedures, are available and are not utilized by the captors.


Facts:

  • William Eilers, a 24-year-old adult, and his pregnant wife were members of a religious group called the Disciples of the Lord Jesus Christ.
  • Concerned about personality changes in Eilers, his relatives contacted Wisconsin authorities about civil commitment but were informed there were no legal grounds to confine him as he was not a danger to himself or others.
  • On August 16, 1982, Eilers' relatives and hired deprogrammers forcibly abducted him and his wife outside a medical clinic in Winona, Minnesota.
  • Eilers was taken to the Tau Center, held in a room with boarded-up windows, handcuffed to a bed for at least two days, and guarded to prevent escape.
  • The defendants intended to hold Eilers for a full week, and he was held against his will for five and a half days.
  • After several days, Eilers feigned consent in order to create an opportunity for escape.
  • While being transported to another state for further deprogramming, Eilers escaped from a vehicle and summoned police with the help of local residents.

Procedural Posture:

  • William Eilers (plaintiff) filed a lawsuit in the United States District Court against the deprogrammers hired by his parents (defendants).
  • The plaintiff's complaint included claims for false imprisonment and conspiracy to deprive him of his constitutional rights under 42 U.S.C. § 1985(3).
  • The case proceeded to a jury trial.
  • At the close of evidence, the plaintiff moved for a directed verdict on his false imprisonment and § 1985(3) claims.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the defense of necessity legally justify the five-and-a-half-day confinement of an adult for the purpose of 'deprogramming' when the captors failed to utilize available legal procedures for civil commitment?


Opinions:

Majority - MacLaughlin, District Judge

No. The defense of necessity does not justify the confinement because even if there was an imminent danger, the defendants were required to use the least restrictive means and deliver the person to lawful authorities, which they failed to do. The court found that all elements of false imprisonment were overwhelmingly established: the defendants intended to confine Eilers, he was actually confined without a reasonable means of escape, and he was aware of the confinement. The court rejected the argument that Eilers' feigned consent was a defense, as it was induced by the illegal confinement itself. The court then analyzed the defendants' necessity defense, which requires: 1) a reasonable belief of imminent physical injury; 2) confinement lasting only as long as necessary to get the person to lawful authorities; and 3) use of the least restrictive means. Assuming the first element was met, the court held that the defendants' conduct wholly failed the second and third elements. The defendants had several lawful alternatives, including contacting the police, initiating civil commitment proceedings, or seeking emergency professional help, but instead held Eilers incommunicado for over five days. The court concluded that where the legislature has prescribed specific procedures for depriving a person of liberty based on mental illness, private citizens, even with good motives, are not entitled to disregard those procedures.



Analysis:

This decision significantly curtails the use of self-help remedies like forcible deprogramming by private individuals. It establishes that the common law defense of necessity is unavailable when established statutory procedures for civil commitment exist and are ignored. The ruling reinforces that good motives are not a defense to the tort of false imprisonment and that the fundamental right to liberty cannot be abrogated by private action, especially when legal avenues have not been pursued. This case serves as a strong precedent against extra-legal interventions in cases involving adults who have joined controversial religious groups or 'cults'.

🤖 Gunnerbot:
Query Eilers v. Coy (1984) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Eilers v. Coy