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Case Citations [i] (Spring 2026)

handle is hein.ali/rethtort9921 and id is 1 raw text is: THE AMERICAN LAW INSTITUTE Spring 2026 Citations TORTS 3D: INTENTIONAL TORTS TO PERSONS CHAPTER 1. DEFINITIONS OF INTENTIONAL TORTS TO PERSONS; TRANSFERRED INTENT § 7. False Imprisonment: General Definition C.A.11, 2025. Cit. in sup. (citing T.D. No. 3, 2018). Filipino seamen who worked on a cruise ship filed claims for false imprisonment and intentional infliction of emotional distress against Florida-based employer that owned the ship, alleging that employer took two months to repatriate them to the Philippines after the ship's operations were suspended by the federal government during a pandemic. The district court granted employer's motion to dismiss for failure to state a claim under maritime law. This court affirmed, holding that seamen did not state a claim for the maritime tort of false imprisonment, because they failed to allege that employer lacked the lawful authority to confine them to the ship. Although Restatement Second of Torts § 35 and Restatement Third of Torts: Intentional Torts to Persons § 7 omitted unlawfulness as an element of false imprisonment, the court noted that a claim for false imprisonment under maritime law incorporated the element of unlawfulness by requiring a plaintiff to allege a willful detention without consent and without lawful authority. Maglana v. Celebrity Cruises Inc., 136 F.4th 1032, 1040. § 9. False Imprisonment: Confinement by Assertion of Legal Authority C.A.11, 2025. Rptr's Note to com. (b) quot. in sup. (citing Rptr's Note to com. (b) of T.D. No. 3, 2018). Filipino seamen who worked on a cruise ship filed claims for false imprisonment and intentional infliction of emotional distress against Florida-based employer that owned the ship, alleging that employer took two months to repatriate them to the Philippines after the ship's operations were suspended by the federal government during a pandemic. The district court granted employer's motion to dismiss for failure to state a claim under maritime law. This court affirmed, holding that seamen did not state a claim for the maritime tort of false imprisonment, because they failed to allege that employer lacked the lawful authority to confine them to the ship. The court observed that the more modern Restatements of Torts omitted unlawfulness as an element of a claim for false imprisonment, and noted that, under Restatement Third of Torts: Intentional Torts to Persons § 9, the lawfulness of a COPYRIGHT C2026 By THE AMERICAN LAW INSTITUTE All rights reserved Printed in the United States of America For earlier citations, see the Appendices, Supplements, or Pocket Parts, if any, that correspond to the subject matter under examination.