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Zittrain Torts Playlist Spring 2013

Susan Louise Peterson, Appellant, v. Paul Sorlien, Respondent, Norman Jungclaus, et al., Respondents, Michele Perkins, Respondent.

Headnote

Should we regard individuals as "falsely imprisoned" when they are provided with many opportunities to escape? Plaintiff joined a cult while in college. As a result, her grades fell, she became increasingly alienated from her family, and she sold her car and took on a part-time job to increase her payments to the cult. Afraid for their daughter, the plaintiff’s parents took her to the house of a self-styled professional deprogrammer. For two days, the plaintiff violently resisted the deprogramming and was forcibly confined. However, over the next thirteen days, plaintiff’s demeanor changed considerably; she became “friendly and vivacious”. Subsequently, plaintiff was no longer confined by force and was free to participate in outdoor activities, take solitary walks, and even fly to another city with another former cult member who had shared her experiences in the former week. At the end of the deprogramming period, plaintiff refused to sign a waiver releasing her parents from liability for the past weeks’ actions, and returned to the cult and her fiance—who was also a member.