## Facts

- Susan Louise Peterson, age 21, became heavily involved in The Way Ministry, a youth-oriented religious group.
- Peterson’s parents believed her involvement caused major changes in her behavior and family relationships.
- The parents, assisted by others (including “deprogrammers”), brought Peterson to a rural residence for an “intervention” intended to persuade her to leave the group.
- Peterson was physically constrained at the outset and was not free to leave at will during the early phase of the 16-day period.
- During the later portion of the 16 days, Peterson participated in public activities and, despite opportunities to leave, made no meaningful effort to escape.
- After the 16-day period ended, Peterson returned to The Way Ministry for a time.
- Peterson sued her parents, Paul Sorlien (a former minister), and others involved, alleging false imprisonment and intentional infliction of emotional distress (IIED).

## Issues

1. Whether the evidence required judgment notwithstanding the verdict (JNOV) for Peterson on false imprisonment despite the jury’s defense verdict.
2. Whether admission of evidence about The Way Ministry, and a credibility instruction permitting consideration of third-party litigation funding, warranted a new trial.
3. Whether the directed verdict for Paul Sorlien was error due to sufficient evidence of his participation in tortious conduct.
4. Whether denial of Peterson’s motion to amend the complaint to substitute named defendants for Doe/Roe parties and add a new cause of action was an abuse of discretion requiring reversal.

## Decision

- The Minnesota Supreme Court affirmed the district court’s judgment in all material respects.
- The court held the jury could reasonably find no false imprisonment because evidence supported an inference that Peterson later consented to remain and was not meaningfully deprived of liberty after the initial period.
- The court upheld the directed verdict for Sorlien because the evidence was insufficient as a matter of law to connect him to actionable conduct.
- Any assumed errors in the credibility instruction and in denying substitution of certain unnamed defendants were not of fundamental magnitude and did not justify reversal.
- The verdict finding two defendants liable for IIED (with nominal compensatory damages and punitive damages) remained undisturbed.

## Legal Principles

- False imprisonment requires a confinement or restraint without consent; later conduct may support a finding that an initially nonconsensual restraint became consensual.
- A plaintiff’s participation in public activities, opportunities to leave, and failure to attempt escape may support a jury finding of consent and no actionable deprivation of liberty.
- A directed verdict is proper when the record lacks legally sufficient evidence connecting a defendant to the alleged tort.
- Appellate review of evidentiary rulings, jury instructions, and pleading-amendment decisions applies a prejudice/harmless-error framework; nonfundamental errors that do not affect the verdict do not warrant a new trial.

## Conclusion

The court upheld a defense verdict on false imprisonment arising from a family-arranged deprogramming because the evidence permitted a finding that any restraint ended when Peterson later acquiesced and had meaningful opportunities to leave, and it affirmed trial rulings, including a directed verdict for a peripheral defendant and harmless-error treatment of challenged instructions and amendment denials.


Peterson v. Sorlien, 299 N.W.2d 123 (Minn. 1980)