False Imprisonment in Rhode Island

Background

“False imprisonment involves an imposition of unlawful restraint upon another's freedom of movement and this restraint need continue for no more than a brief time.” (See Webbier v. Thoroughbred Racing Protective Bureau, Inc. (1969) 105 R.I. 605, 606.)

“If a person is unlawfully detained by another and is fearful that physical force will be used unless he submits to the detention, his submission thereto will not bar his cause of action.” (See id.)

General Information for Complaints and Motions

“In Barth v. Flad, 99 R.I. 446, 208 A.2d 533, this court pointed out that the essence of an action for false imprisonment is the restraint of another without legal justification.” (See Webbier v. Thoroughbred Racing Protective Bureau, Inc. (1969) 105 R.I. 605, 613.)

“The tort involves an imposition of unlawful restraint upon another's freedom of movement.” (See id.)

Prima Facie Case

“In order to recover on his claims for false imprisonment and false arrest, [one] needs to prove that:

1. the defendant intended to confine him,
2. the plaintiff was conscious of the confinement,
3. the plaintiff did not consent to the confinement, and
4. the confinement was not otherwise privileged."

(See Dyson v. City of Pawtucket (1996) 670 A.2d 233, 239; Beaudoin v. Levesque (1997) 697 A.2d 1065, 1067.)

“One also needs to show that he was detained without legal justification. [T]he essential element of this tortious action is the restraint of another person without legal justification or without any color of legal authority.” (See id.)

Standard of Review and Burdens of Proof

“Summary judgment is appropriate when no genuine issue of material fact is evident from the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits if any, and the motion justice finds that the moving party is entitled to prevail as a matter of law.” (See Burdick v. Town of Westerly, C.A. No. WC-2016-0043, at *1 (R.I. Super. Jan. 15, 2021).)

“In considering a party's Rule 50 motion for judgment as a matter of law, the trial justice must consider the evidence in the light most favorable to the nonmoving party, without weighing the evidence or evaluating the credibility of the witnesses, and draw from the record all reasonable inferences that support the position of the nonmoving party." (See Cook v. First Student, Inc., C.A. No. P2000-5861, at *4 (R.I. Super. Mar. 7, 2007).)

“If, after such a review, there remain factual issues upon which reasonable persons might draw different conclusions, the motion for judgment as a matter of law must be denied.” (See id.)

“If, on the other hand, no relevant issues of fact exist and defendant is entitled to judgment as a matter of law, then the trial justice should grant the motion and dismiss the complaint.” (See id.)

The Court’s Decisions

It is well settled that “the essential element of false imprisonment is the restraint of another person without legal justification.” (See Barth v. Flad (1965) 99 R.I. 446, 448.)

“Long ago this court said that false imprisonment is the unlawful detention of another without his consent, and malice is not an essential element thereof. The essential element of this tortious act is that the arrest complained of is made without legal process or under a void process.” (See Powers v. Carvalho (1977) 117 R.I. 519, 526.)