Meints v. Huntington et al.

276 F. 245
Circuit Court of Appeals, 8th Circuit
September 3, 1921

Procedural History:
John Meints (Plaintiff) brought this action against Huntington and others (Defendants) on the charge that they deported
him to South Dakota and mistreated him on the way. After the trial, there was a verdict and judgment for defendants.
The judgment is now reversed, and the cause remanded for a new trial.

Facts:
In Summer 1918, Meints, at the time, a resident of Luverne, Minnesota, was suspected of being interested in or
supportive of an anti-WWI newspaper. Midnight, June 19th, a large group of men including some of the defendants
went to his house and transported him across state lines into Iowa and told him not to return. After this incident,
Meints went to live with his sons. On August 19, 1918 a group of 75-80 men went to Meint’s sons’ home. Meints and
his sons saw the caravan of 25 cars coming and fastened the screen door shut. Defendant Long forced the door open,
allowing other men to enter. They assaulted the son and threw him out of the house. Meints was armed with a gun and
fork handle and refused to come down or allow anyone to come up the stairs. The other son and a few defendants
spoke to Meints. Following this, Meints came down with Long and was taken into Huntington’s car to Luverne. Meints
was held in Luverne and was refused permission to contact his wife. Meints was put back into the defendant’s car and
was transported to South Dakota where he was assaulted, whipped, tarred and feathered, and told to never return to
Minnesota again.

Issue(s):

1) Was Meints falsely imprisoned by the Defendants?

2) Was the trial court in error when it instructed the jury that everything that happened to Meints before reaching
South Dakota was not unlawful false imprisonment because Meints had consented?
3) Was the trial court in error when it allowed Defendants to use the Plaintiff’s alleged disloyalty to the war in
support of their defense that they falsely imprisoned Meints to protect him from others who might injure him
because of his disloyalty?

Holding(s):
1) Yes
2) Yes
3) Yes

Key Rules or Principles:

1) Comer v Knowles, 17 Kan. 436- “False imprisonment is necessarily a wrongful interference with the personal
liberty of an individual…It is not necessary that the individual be confined within a prison, or within walls; or that
he be assaulted or even touched…all that is necessary is, that the individual be restrained of his liberty without
any sufficient legal cause therefor, and by words or acts which he fears to disregard.”
2) Cooley, Torts- “False imprisonment is a wrong akin to the wrongs of assault and battery, and consists in
imposing, by force or threats, an unlawful restraint upon a man’s freedom.”
3) The law does not sanction the claim, either in defense or mitigation, that the rights of one may be violated for
the purpose of preventing others from doing the same thing.

Reasoning:
1) Evidence is clear that the Defendants would not have allowed any resistance from Meints. He was a prisoner
from the time the Defendants reached his sons’ house to until he crossed into South Dakota. Interference with
one’s liberty is sufficient to constitute false imprisonment.
 2) Although Meints did not resist restraint, he did not consent to unlawful acts of false imprisonment and assault.
Meints did as he was told from the beginning, but did not consent to being imprisoned. This was a prejudicial
error.
3) Contrary to the Plaintiff’s objection, the trial court allowed the fact that Meints was disloyal to the war to reduce
in harshness the Defendants’ actions. Hatred or dislike of someone for personal problems is not an element of
false imprisonment, so this piece of evidence is irrelevant.

Concurrence or Dissent:
Cotteral, District Judge, concurs in the result.

My Notes:
I agree with the reversal of the previous judgment. Although Meints was disloyal to the war effort, that was not a
sufficient reason by the law to be falsely imprisoned or assaulted. He did not consent to being imprisoned or assaulted
by the Defendants.