Barrett v. Watkins
Appellate Divisions of the Supreme Court of the State of New York
82 A.D.3d 1569 (2011)
When Barrett (plaintiff) tried to leave a remote park, he found the access road blocked by a truck owned by Ebert, who Barrett testified said he worked for Dubrovsky (defendant); Dubrovsky arrived, told Barrett he didn't care if Barrett sat there all night, and then left with Ebert, abandoning Barrett at the scene until police eventually arrived and made Ebert move the truck. Ebert told police he had been ordered to block the road specifically to prevent Barrett from leaving. Dubrovsky sought summary judgment, denying any employment relationship with Ebert, denying he had directed Ebert's actions, and arguing Barrett was never actually confined because Dubrovsky believed another way out of the park existed. The lower court granted Dubrovsky's motion.
Whether, for the purposes of false imprisonment, a plaintiff may be considered confined if the defendant did not inform the plaintiff of an exit, the plaintiff was not aware of an exit, and the means of exiting were not reasonable.