Peterson v. Sorlien
299 N.W.2d 123 (1980)
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Rule of Law:
When parents act under the conviction that their adult child's judgmental capacity is impaired due to a religious cult, their actions to extricate the child do not constitute false imprisonment if the child assents to the actions at some point.
Facts:
- Susan Jungclaus Peterson, a 21-year-old college student, became deeply involved with an organization known as The Way Ministry.
- Her parents, Norman and Susan Jungclaus, observed significant negative personality changes, alienation from family, and declining academic performance, which they attributed to the group's influence.
- Believing Peterson was a victim of 'coercive persuasion' and in a state of 'psychological bondage,' the Jungclauses decided to intervene.
- On May 24, 1976, Norman Jungclaus picked Peterson up from college and drove her to the home of Veronica Morgel, where a group including a 'deprogrammer' named Kathy Mills was waiting.
- For the first two days, Peterson was hysterical and non-cooperative, crying, screaming, plugging her ears, and remaining curled in a fetal position.
- After the initial two days, Peterson's demeanor changed completely; she became friendly, engaged in conversations, and willingly participated in public activities such as roller-skating, playing softball, and flying to Ohio.
- After 16 days, Peterson's parents asked her to sign a release of liability for their actions, which she refused.
- Immediately after refusing to sign the release, Peterson motioned to a passing police car and was reunited with her fiancé from The Way Ministry.
Procedural Posture:
- Susan Jungclaus Peterson sued her parents, Veronica Morgel, Kathy Mills, Paul Sorlien, and others in Hennepin County District Court (a trial court) for false imprisonment and intentional infliction of emotional distress.
- The trial court directed a verdict in favor of defendant Paul Sorlien.
- A jury returned a verdict finding the remaining defendants not liable for false imprisonment.
- The jury found defendants Veronica Morgel and Kathy Mills liable for intentional infliction of emotional distress, awarding compensatory and punitive damages.
- Peterson moved for a judgment notwithstanding the verdict on the false imprisonment claim, which the trial court denied.
- Peterson, as appellant, appealed the trial court's judgment to the Minnesota Supreme Court.
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Issue:
Do the actions of parents who confine their adult child for 'deprogramming' from a religious cult constitute false imprisonment if the parents reasonably believe the child's judgmental capacity is impaired and the child later assents to the confinement?
Opinions:
Majority - Sheran, C.J.
No. When parents, acting under a reasonable belief that their adult child's judgmental capacity is impaired by a cult, seek to extricate that child, limitations on the child's mobility do not constitute false imprisonment if the child eventually assents. The court reasoned that the 'coercive persuasion' used by the cult undermined Peterson's capacity for informed consent. Her subsequent willing participation in activities for 13 of the 16 days demonstrated a valid, albeit delayed, consent. This subsequent affirmation of the defendants' actions was deemed dispositive, effectively ratifying the initial period of confinement after her volitional capacity was restored through the deprogramming process. The court concluded that society has a compelling interest in intervention in such cases but cautioned that it does not endorse self-help as a preferred alternative.
Concurring - Peterson, J.
Concurred in the result without providing a separate written opinion.
Concurring-in-part-and-dissenting-in-part - Wahl, J.
Yes, the actions constituted false imprisonment. The dissent argues that the unrebutted evidence shows Norman Jungclaus held his 21-year-old daughter against her will for the first few days, which are the essential elements of the tort. Good faith or motive is not a defense to false imprisonment. The majority's theory that later acquiescence 'relates back' to nullify the initial confinement is legally unsound and sets a dangerous precedent allowing parents to engage in tortious conduct based on their subjective disapproval of their adult children's religious beliefs.
Dissenting - Otis, J.
Yes, the actions constituted false imprisonment. The dissent argues that the majority creates a vague and dangerous rule authorizing confinement whenever a parent subjectively decides an adult child's 'judgmental capacity' is impaired by an 'unorthodox' group. At 21, Peterson was an adult with the constitutional right to make her own choices, however unconventional. The majority's holding erodes the basic rights of adults to think and associate freely without interference from 'meddling friends or relatives,' regardless of their intentions.
Analysis:
This case establishes a controversial, limited privilege for parents to use self-help to 'deprogram' adult children from groups they reasonably believe are cults that have impaired the child's free will. The decision marks a significant, albeit narrow, departure from traditional false imprisonment doctrine by allowing a defendant's motive and a plaintiff's subsequent consent to negate an initial, otherwise tortious, confinement. It highlights the legal system's struggle to balance the First Amendment rights of religious association and belief against the perceived social harm of 'coercive persuasion' and the protective interests of family members. The strong dissents underscore the precedential danger of allowing subjective beliefs about another's mental state to justify the deprivation of liberty.
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