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Eilers v. Coy

District Court of Minnesota
582 F. Supp. 1093 (1984)


William Eilers (plaintiff) and his wife were abducted from outside a clinic by family members and deprogrammers (Coy) (defendants) who had been hired by the family members. At the time, Eilers and his wife were members of an authoritarian religious fellowship, and the family members believed that Eilers was suicidal because of a letter he had written months earlier suggesting that demons were attacking his mind and telling him to kill himself. However, after Eilers had written the letter, a psychiatric social worker had determined that Eilers was not a threat to himself or others and reported those findings to the family members. After the abduction, Eilers was taken to the top floor of a dormitory-style building, where he was confined to a room with boarded windows and handcuffed to a bed. For the next two days, Eilers remained handcuffed to the bed and was only allowed out of the room to use the bathroom. Eilers attempted to escape but was forcibly returned to his room. After five-and-a-half days, Eilers was taken out of the building to be transferred to another city for additional deprogramming. During the transfer, Eilers jumped from a vehicle and was assisted by third parties. The police were then contacted and became involved. Eilers eventually brought a claim of false imprisonment against Coy. As a defense against the claim, Coy invoked the doctrine of necessity, arguing that Eiler’s confinement was necessary because he was a danger to himself or others.

Rule of Law


Holding and Reasoning (MacLaughlin, J.)

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