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Peterson v. Sorlien
Minnesota Supreme Court
299 N.W.2d 123 (1980)
Susan Jungclaus Peterson (plaintiff) finished second in her high school class, then attended college at Moorhead State College. During her freshman year, Peterson joined a group called The Way. The Way was a pseudo-religious organization focused on recruitment and fundraising using specially designed learning programs. The learning programs consisted of taped courses and training sessions. As Peterson became more involved with The Way, her grades declined, her personality changed, she was overtired and pale, and she distanced herself from her family. Peterson got engaged to another member of The Way. Peterson’s parents, the Jungclauses (defendants) were alarmed by these changes in their daughter. They believed that The Way was a cult, and that Peterson was in a state of psychological bondage. At the end of one of Peterson’s college quarters, her father picked her up, accompanied by Paul Sorlien, Peterson’s former minister. Instead of driving her home, the Jungclauses drove Peterson to the home of Veronia Morgel (defendant). At Morgel’s house, Peterson was met by Kathy Mills (defendant) a self-styled cult deprogrammer, and a group of young people who had each been involved with or touched by cults in the past. Peterson was unwilling to talk about her involvement with The Way. She spent two days in a fetal position, crying, plugging her ears, and refusing to listen to what the group was telling her. Suddenly Peterson’s demeanor changed. She was social, went rollerskating and on a picnic, and played softball. She then spent a week in Columbus, Ohio. In Columbus, Peterson spoke with her fiancé daily over the phone. He tried to persuade her to return to The Way. After returning to Morgel’s house, Peterson walked out of the house, flagged down a policeman, and reunited with her fiancé in Minneapolis. She then sued her parents, Morgel, and Mills, for false imprisonment and intentional infliction of emotional distress. The jury found that the defendants were not liable for false imprisonment, but held Morgel and Mills liable for the intentional infliction of emotional distress. Peterson appealed, arguing, among other things, that the trial court should have granted a judgment against the defendants notwithstanding the verdict on the claim of false imprisonment.
Rule of Law
Holding and Reasoning (Sheran, C.J.)
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