Vumbaca v. Terminal One Group Association LP

Bad weather forced planes at JFK Airport to remain on the tarmac for hours; Vumbaca (plaintiff) and other passengers were kept aboard for nearly seven hours in cramped conditions without food, water, or sanitation. Vumbaca sued Terminal One (defendant), the terminal operator, for false imprisonment, and the defendant moved to dismiss.

Whether a claim of false imprisonment requires the plaintiff to show that the defendant intended to unlawfully confine the plaintiff.