Case Citation
Legal Case Name

PETERSON v. SORLIEN Case Brief

Supreme Court of Minnesota1980
299 N.W.2d 123 Torts Family Law Constitutional Law

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Case Brief Summary & Legal Analysis

Torts Focus
3 min read

tl;dr: Parents deprogrammed their 21-year-old daughter from a religious group. The court found no false imprisonment, holding that her impaired judgment during an initial confinement, followed by her willing participation, negated the claim and created a limited parental privilege.

Legal Significance: Establishes a narrow, controversial defense to false imprisonment, allowing parents to confine an adult child for deprogramming from a cult if they reasonably believe the child’s judgmental capacity is impaired and the child later assents to the confinement.

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Case Facts & Court Holding

Key Facts & Case Background

Plaintiff Susan Peterson, a 21-year-old college student, became deeply involved in a religious group known as The Way Ministry. Her parents, alarmed by her significant personality changes and alienation, concluded she was a victim of ‘coercive persuasion’ that had impaired her volitional capacity. The plaintiff’s father took her to a private home for a 16-day ‘deprogramming.’ For the first three days, the plaintiff was held against her will; she was confined to a room, cried, screamed, and was physically restrained at one point. Following this initial period, her demeanor changed completely. For the remaining 13 days, she willingly participated in public activities, including roller-skating, playing softball, and flying to another state. During this time, she had numerous opportunities to contact authorities or escape but did not do so. After being reunited with the group, she sued her parents and the deprogrammers for false imprisonment and intentional infliction of emotional distress. A jury found for the defendants on the false imprisonment claim.

Court Holding & Legal Precedent

Issue: Does the temporary, non-consensual confinement of an adult child by her parents for the purpose of ‘deprogramming’ constitute false imprisonment when the child’s volitional capacity is allegedly impaired and she subsequently assents to the confinement?

No. The court affirmed the jury’s verdict for the defendants on the Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fug

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IRAC Legal Analysis

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Legal Issue

Does the temporary, non-consensual confinement of an adult child by her parents for the purpose of ‘deprogramming’ constitute false imprisonment when the child’s volitional capacity is allegedly impaired and she subsequently assents to the confinement?

Conclusion

This case establishes a narrow and controversial defense to false imprisonment, allowing Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco

Legal Rule

When parents, acting under the conviction that their adult child's judgmental capacity Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dol

Legal Analysis

The court's analysis of the false imprisonment claim centers on the defense Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur

Flash-to-Full Case Opinions

Flash Summary

  • A limited privilege exists for parents to confine an adult child
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu

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