## Facts

- On the last day of school, 14-year-old James Sindle rode a school bus owned by the New York City Transit Authority and driven by its employee, Mooney.
- Approximately 65–70 students were on the bus; the ride was loud, and some students vandalized the bus by damaging lights, windows, and ceiling panels.
- Mooney repeatedly warned students to stop, but the disorder continued; at one stop he inspected the damage and announced he would take the students to a police station.
- Mooney bypassed several regular stops while driving toward the police station.
- Some students began exiting through a rear side window; Sindle attempted to do so and fell as the bus turned, after which the rear wheels ran over him, causing serious injuries.
- Sindle and his father sued for false imprisonment (not negligence), alleging Mooney unlawfully confined the students by taking them toward the police station.
- At trial, defendants sought to amend their answer to plead justification and to introduce evidence of student misconduct and bus damage; the court denied the amendment and excluded that evidence, resulting in a plaintiff’s judgment affirmed by the Appellate Division.

## Issues

1. Whether the trial court abused its discretion by denying leave to amend the answer to assert justification and by excluding evidence relevant to that defense.
2. Whether a restraint imposed to prevent personal injury or property damage, if reasonable in purpose, manner, and duration, can be lawful and therefore not actionable as false imprisonment.
3. Whether the reasonableness of a school bus driver’s detention of student passengers under disorderly conditions is for the fact-finder to decide on a full evidentiary record.

## Decision

- The Court of Appeals reversed and ordered a new trial.
- The trial court abused its discretion by refusing to permit amendment to plead justification and by excluding evidence of the students’ misconduct and the resulting damage.
- Reasonable restraint or detention to prevent injury or property damage may be justified and, if so, is not “unlawful” confinement for false imprisonment purposes.
- The case was remitted so the fact-finder could assess, on a complete record, whether the driver’s conduct (including bypassing stops and heading to the police) was reasonable under the circumstances.

## Legal Principles

- False imprisonment requires unlawful confinement; confinement accomplished by controlling a vehicle can satisfy the restraint element, but lawfulness depends on any applicable privilege.
- A person may be justified in restraining or detaining another, in a manner reasonable under the circumstances, to prevent personal injury or damage to property.
- Justification is an affirmative defense; the defendant bears the burden to plead and prove it.
- In custodial or supervisory settings involving minors, those responsible for children’s safety and welfare may exercise reasonable control to maintain order and protect persons and property; the permissible scope turns on reasonableness.

## Conclusion

The court held that defendants were entitled to present and litigate an affirmative defense that the bus driver’s detention of disorderly students was a reasonable measure to prevent further harm, and it ordered a new trial because the trial court’s refusal to allow the justification defense and related evidence improperly removed the central dispute from the jury.


Sindle v. N.Y.C. Transit Auth., 33 N.Y.2d 293 (1973)