Sindle v. New York City Transit Authority Case Brief

Summary of Sindle v. New York City Transit Authority, 33 N.Y.2d 293, 307 N.E.2d 245 (1973)

Facts: Plaintiff was 14 years old student who was riding in a school bus owned by the defendant. This was the last day of school and some students, out of excitement, damaged the bus. The driver told the students that he was going to take the bus to the police station. He locked the doors and started driving towards the station. When the bus slowed down to turn, some students jumped out he window. The plaintiff also decided to jump out the window but the bus hit a curb and defendant fell or jumped out the window and the rear tire of the bus rolled over the plaintiff rendering him severe bodily injuries. Plaintiff brought an action for false imprisonment against the defendant.

Procedure: The trial court denied the defendant’s motion to amend and to exclude the evidence of justification and ruled for the plaintiffs.

Issue: Did the trial court err by denying the defendant’s motion of justification?

Holding: yes

Rationale: The denial of the motion by the trial court prevented the defendants from introducing evidence for justification and was unfair. The court then outlined some issues that can be considered under justification. For example, restraint or detention can be reasonable under circumstances for the purpose of preventing another from inflicting personal injuries or interfering with or damaging real or personal property. A school bus driver has the duty to protect both the students and also the bus property. In determining the damages, plaintiff’s negligence can also be considered. “…the person falsely imprisoned is not relived of the duty of reasonable care for his own safety in extricating himself from the unlawful detention." So the negligent actions of the plaintiff can also be considered in the new trial. Reversed and new trial granted.

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