Eilers v. Coy
District Court of Minnesota
582 F. Supp. 1093 (1984)
William Eilers (plaintiff) and his wife, members of an authoritarian religious group, were abducted by family members and hired deprogrammers (Coy) (defendants) who believed Eilers was suicidal based on a letter he'd written months earlier - even though a psychiatric social worker had since cleared him as no threat to himself or others, a finding reported to the family. Eilers was confined for over five days, handcuffed to a bed in a room with boarded windows, allowed out only to use the bathroom, and forcibly returned after attempting escape, before eventually jumping from a transport vehicle and being rescued by third parties who contacted police. Eilers sued for false imprisonment, and Coy invoked the necessity defense, arguing the confinement was needed to prevent Eilers from harming himself or others.
Whether the defense of necessity precludes liability for false imprisonment when the defendant had lawful alternatives available for preventing the confined person from causing harm.