## Facts

- Kathleen Eilers, an adult, lived independently and was associated with a religious group her relatives viewed as harmful.
- Relatives contacted and arranged for William Coy and other deprogrammers to remove Eilers from the group’s influence.
- Eilers alleged she was lured or seized, taken against her will to a motel or similar location, and held there for several days.
- During confinement, Eilers alleged her movement was restricted by guards or locked doors and she was not free to leave.
- Eilers alleged defendants pressured her to abandon her beliefs through interrogation, intimidation, and coercive tactics.
- Eilers regained her freedom (by escape or release) and sued deprogrammers and alleged participating relatives for damages, asserting state-law tort claims and federal civil-rights claims.

## Issues

1. Whether the alleged abduction and confinement of a competent adult stated viable claims for false imprisonment and related torts.
2. Whether defendants could justify nonconsensual confinement based on relatives’ belief that Eilers was “brainwashed” or effectively incapable of voluntary choice.
3. Whether any defendant acted “under color of state law” so as to support liability under 42 U.S.C. § 1983 for alleged deprivations of liberty and religious freedom.

## Decision

- The court allowed the state-law tort claims, including false imprisonment and related claims premised on coercive confinement, to proceed because the record raised triable fact disputes about nonconsensual restraint without lawful authority.
- The court rejected a broad theory that relatives or hired deprogrammers may forcibly confine a competent adult based on disagreement with her religious affiliation or a claimed need to “deprogram” her.
- The court treated the § 1983 claims more narrowly, holding that private deprogrammers and relatives were not automatically state actors and that federal civil-rights liability required sufficiently alleged or proven state involvement (such as joint participation with law enforcement).

## Legal Principles

- False imprisonment requires intentional confinement within fixed boundaries, without consent, and without lawful justification; evidence of guarded or locked confinement can create a triable issue.
- Private parties generally lack legal authority to confine a competent adult absent lawful process (e.g., civil commitment or a guardianship/incompetency adjudication).
- There is no general “deprogramming” privilege that legalizes nonconsensual confinement based on claims of “brainwashing” or a belief that the confinement is beneficial.
- Liability under 42 U.S.C. § 1983 requires action under color of state law; private conduct becomes state action only with a sufficient nexus, such as joint participation or significant assistance by state officials.

## Conclusion

The court permitted Eilers to pursue tort remedies for an alleged forcible deprogramming and confinement, while limiting federal civil-rights theories to circumstances where defendants could be tied to state action; it refused to recognize a private right to restrain a competent adult based on objections to her religious affiliation.


Eilers v. Coy, 582 F. Supp. 1093 (D. Minn. 1984)