Peterson v. Sorlien – Case Brief

Peterson v. Sorlien, 299 N.W.2d 123 (Minn. 1980).

Facts: Susan Jungclaus Peterson (P) was a Dean’s List student at Moorhead State College with a promising future until she joined a cult named The Way of Minnesota, Inc. The group required members to solicit on behalf of the organization and turn over 10% of their earnings and imposed other financial obligations.

Peterson became a full member of the group. Her father, Norman Jungclaus (D), brought her to Kathy Mills (D), a cult deprogrammer, when her grades, appearance, and overall demeanor began to suffer. Peterson stayed in the home of Morgel (D) during the deprogramming period. After some initial success Peterson returned to the group to be reunited with her fiancee.

Peterson brought suit against the defendants for the intentional torts of false imprisonment and intentional infliction of emotional distress. At trial the defendants established that Peterson had remained with the deprogrammer voluntarily for at least 13 of the 16 days with ample opportunity to escape and contact the police.

At trial the jury found that Morgel and Mills were liable for intentional infliction of emotional distress and awarded $1 in compensatory damages. The jury also found Morgel and Mills liable for $4,000 and $6,000 in punitive damages respectively. The court ordered a directed verdict in favor of Peterson’s mother and father and her former minister, Sorlien (D). The jury exonerated all of the defendants with regard to the false imprisonment claims. Peterson appealed.

Issue: Do the reasonable acts of a parent or agent of the parent to save an adult child from a religious cult, followed by the subsequent acceptance of those acts by the adult child, constitute a defense to a charge of false imprisonment?

Holding and Rule (Sheran): Yes. The reasonable acts of a parent or agent of the parent to save an adult child from a religious cult, followed by the subsequent acceptance of those acts by the adult child, constitute a defense to a charge of false imprisonment.

When parents or their agents, acting under the conviction that the judgmental capacity of their adult child is impaired, seek to extricate that child from what they reasonably believe to be a religious or pseudo-religious cult, and the child at some juncture assents to those actions, limitations upon the child’s mobility do not constitute meaningful deprivations of personal liberty sufficient to support a judgment of false imprisonment. In this case Peterson’s acquiescence after the third day with the deprogrammer provides the defendants with a complete defense to false imprisonment.

Dissent (Wahl): Adults in our society enjoy freedoms of association and belief. The fact that the defendants acted in good faith is not a defense to false imprisonment.

Dissent (Otis): Peterson was a 21 year old adult and no longer a child. She was falsely imprisoned.

See Whittaker v. Sandford for another case featuring an issue of false imprisonment involving a cult member.


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