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Whittaker v. Sandford

Supreme Judicial Court of Maine
85 A. 399 (1912)


Facts

Whittaker (plaintiff) and her husband were members of a religious sect with a colony in Maine and overseas. Whittaker joined the sect located overseas but decided to abandon the sect and return to America on a steam ship. Sandford (defendant), the sect leader, offered to take Whittaker back to America on his yacht. Whittaker told Sandford that she was afraid he would not let her off the yacht until she returned to the religious sect. Sandford assured her she would not be detained, and she sailed to America on the yacht. Once the yacht arrived in port, Sandford refused to supply Whittaker with a row boat to leave the yacht. He told her it was up to her husband and her husband in turn said it was up to Sandford. Whittaker was on the yacht for nearly a month during which time she was only allowed to go ashore with her husband, but not by herself. Whittaker finally got her release with the help of the sheriff and a writ of habeas corpus. Whittaker sued Sandford for false imprisonment and won a judgment against Sandford. Sandford appealed the judgment to the Supreme Judicial Court of Maine.

Rule of Law

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Issue

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Holding and Reasoning (Savage, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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