Teichmiller v. Rogers Memorial Hospital

Elaine Teichmiller (plaintiff) was a nurse working for Rogers Memorial Hospital, Inc. (Rogers) (defendant). Teichmiller believed that Rogers was forcing her to falsify medical records, and Teichmiller quit her job because she felt her only choices were to quit or to falsify the medical records. Teichmiller went to a meeting to discuss her departure with her supervisor, Christine Hansburg-Hotson, as well as Hansburg-Hotson’s supervisor, Debbie Bergerson-Hawkins (defendant), and Bergerson-Hawkins’s supervisor, Sue Otto (defendant). During the meeting, Teichmiller was given a form to sign and told that she would have to complete her medical charts before leaving. Teichmiller refused to sign the form, and she said she was following the advice of her attorney. Bergerson-Hawkins and Otto began yelling at Teichmiller about this. Teichmiller said she planned to make a copy of the form, and Otto and Bergerson-Hawkins got up. Bergerson-Hawkins blocked the doorway on Teichmiller’s right, and Otto stood on Teichmiller’s left. Teichmiller was pinned in because she had a desk in front of her and a chair behind her. They yelled at her that she was stealing hospital property and tried to grab the form from her. Bergerson-Hawkins and Otto did not touch Teichmiller. After three attempts, over the course of three to four minutes, Teichmiller was able to leave the room when Bergerson-Hawkins stepped aside. Bergerson-Hawkins and Otto then followed Teichmiller to the copier where they stood on either side of her. Teichmiller then went to the women’s bathroom, and Otto and Bergerson-Hawkins stood outside the door there. At no point was Teichmiller touched or threatened with physical contact, and at no point did she explicitly ask to leave the space she was in. Teichmiller filed a claim for false imprisonment against Rogers, Bergerson-Hawkins, and Otto, and the court granted summary judgment dismissing the claim. Teichmiller appealed.