Whittaker v. Sandford

Whittaker (plaintiff), leaving a religious sect abroad, sailed home on Sandford's (defendant) yacht after Sandford assured her she would not be detained. Once anchored offshore, Sandford refused to provide a row boat, the only way to reach shore, and for nearly a month Whittaker could go ashore only accompanied by her husband, never alone, until she secured release with a sheriff's help via habeas corpus. She won a false-imprisonment judgment against Sandford, who appealed.

Whether a party may recover for false imprisonment when restrained by another without the use of actual physical force.