## Facts

- The Scofield family suffered a serious truck accident in Baja California, Mexico; the mother died, one child had a severe head injury, and two minor daughters (Erin and Laura) had lesser injuries.
- The children were taken to a local clinic, while the father, Robert Scofield, arranged air transport from the United States.
- Robert contracted for an air ambulance flight through Air Evac (not Critical Air) based on his understanding of available transport options.
- Critical Air, without authorization from Robert, dispatched its own aircraft to the airport where the children expected to board the arranged flight.
- Erin and Laura boarded Critical Air’s aircraft believing it was the transport their father had authorized; they were not told it was a different provider.
- The children alleged they would not have boarded had they known the flight was not the authorized Air Evac transport.
- The children were flown to the United States and taken by ambulance to hospitals.
- The minors, through their guardian ad litem, sued Critical Air and related defendants; a jury found for the minors on false imprisonment and awarded each $60,000.

## Issues

1. Whether false imprisonment under California law may be committed by fraud, deceit, or unreasonable duress, without physical force or threats.
2. Whether the plaintiff must be aware of the confinement at the time it occurs, or whether later awareness plus resulting harm suffices.
3. Whether substantial evidence supported the jury’s finding that the minors were unlawfully restrained.
4. Whether the trial court’s false-imprisonment instruction, though general and incomplete, was legally adequate and nonprejudicial.

## Decision

- The Court of Appeal affirmed the judgment for the minors.
- The court held false imprisonment may be accomplished by fraud, deceit, or other unreasonable duress, not only by force or threats.
- The court held the knowledge element is satisfied if the plaintiff becomes aware of the restraint at some point (contemporaneously or later) and suffers resulting harm.
- The court found substantial evidence that Critical Air induced the minors to board by deception regarding authorization and identity of the transport provider.
- The court held the controlling instruction was correct in law and any incompleteness did not warrant reversal.

## Legal Principles

- False imprisonment is the unlawful restraint or confinement of a person.
- Unlawful restraint may be effected by force, threats, fraud, deceit, or other unreasonable duress.
- Consent obtained through material deception does not constitute valid consent to the confinement.
- The plaintiff must have knowledge of the restraint at some time and must suffer resulting harm or damage; contemporaneous awareness is not required.
- A civil judgment based on a jury verdict will be upheld if supported by substantial evidence, and instructional error warrants reversal only if prejudicial.

## Conclusion

The court upheld a false-imprisonment verdict where minors were induced by deception to board an unauthorized air-ambulance flight, confirming that confinement by fraud is actionable and that later awareness of the restraint can satisfy the knowledge requirement when harm is shown.


Scofield v. Critical Air Med., Inc., 45 Cal. App. 4th 990, 52 Cal. Rptr. 2d 915 (Ct. App. 1996)