Cultic Studies Journal, Vol. 8, No. 1, 1991, Page 47
refused to consider the case on November 30, 1989 and ordered the appellate decision to
be depublished. While the case has lost its value as precedent, the judgment of what is now
$5 million (including interest) against the Krishna organization still stands. To the chagrin of
cult defenders and the Krishnas, this may mean the forced sale of some of its real property,
including temples, monasteries, schools, and its world headquarters in Los Angeles.
At the age of 14, Robin George visited a Krishna temple in Laguna Beach with a friend and,
after repeated visits, became a full member. The head of the temple convinced the girls
their parents were demons, told them it was permissible to deceive non-believers such as
their parents who were blind to the “truth,” and persuaded them to run away from home to
a Krishna hiding Place.
For over a year, Robin‟s parents tried to get the Krishnas to reveal Robin‟s whereabouts, but
instead they moved her from temple to temple around the country and eventually to
Canada while telling her parents they had no idea where she was. While Robin was in the
cult, her father was diagnosed with a heart condition, a fact Robin‟s mother made clear to
the Krishna leaders.
Upon learning from a friend of Robin‟s that she was being hidden in Canada, the Georges
called the police, who threatened the Krishnas with criminal prosecution if they did not
produce the girl. After the Krishnas‟ attorney instructed Robin to lie to the police about the
circumstances of her indoctrination, she fled and eventually returned home.
Less than four months later, Robin‟s father suffered a heart attack, followed by several
strokes, and he died the following September. An expert at trial testified that two years of
anxiety over his daughter aggravated his heart condition and caused him an early death.
Robin and Marcia George became anti-cult activists. On the eve of a Citizens Freedom
Foundation press conference at which the Georges were to speak, the Krishnas put out an
“official statement” concerning Robin claiming she had run away from her parents because
of “cruelty, beatings, harsh treatment.”45
In October 1977, Robin and Marcia George sued the Krishnas for false imprisonment of
Robin, intentional infliction of emotional distress to both, libel to both, and Robin sued for
the wrongful death of her father.
The jury returned a verdict in favor of the Georges on all causes of action and awarded
them in excess of $32.5 million. The Georges accepted a remittitur reducing both punitive
and compensatory damages to a total of $7.9 million.
The tort of false imprisonment derives from the crime of “unlawful violation of the personal
liberty of another”46 and this involves, with one exception, direct physical restraint or the
threat of physical restraint. The exception is when false imprisonment is accomplished by
fraud or deceit.47
The court of appeal found that Robin had not sufficiently established she had been falsely
imprisoned in that 1) there was no proof offered of force or threat of force 2) she was over
14 when enticed to leave home, an age the court found to be “capable of consenting to
conduct that would otherwise be tortious” and 3) she resented no evidence of fraud as to
herself.
Robin sought to distinguish the Molko court‟s finding on false imprisonment as based solely
on protected religious speech, whereas her brainwashing theory involved more than simple
threats of divine retribution. The court determined she had not proved her case, and went
on to describe Molko as
a reaffirmation that physical force or the threat of it is a necessary element of a
false imprisonment cause of action even in the context of a brainwashing claim.
refused to consider the case on November 30, 1989 and ordered the appellate decision to
be depublished. While the case has lost its value as precedent, the judgment of what is now
$5 million (including interest) against the Krishna organization still stands. To the chagrin of
cult defenders and the Krishnas, this may mean the forced sale of some of its real property,
including temples, monasteries, schools, and its world headquarters in Los Angeles.
At the age of 14, Robin George visited a Krishna temple in Laguna Beach with a friend and,
after repeated visits, became a full member. The head of the temple convinced the girls
their parents were demons, told them it was permissible to deceive non-believers such as
their parents who were blind to the “truth,” and persuaded them to run away from home to
a Krishna hiding Place.
For over a year, Robin‟s parents tried to get the Krishnas to reveal Robin‟s whereabouts, but
instead they moved her from temple to temple around the country and eventually to
Canada while telling her parents they had no idea where she was. While Robin was in the
cult, her father was diagnosed with a heart condition, a fact Robin‟s mother made clear to
the Krishna leaders.
Upon learning from a friend of Robin‟s that she was being hidden in Canada, the Georges
called the police, who threatened the Krishnas with criminal prosecution if they did not
produce the girl. After the Krishnas‟ attorney instructed Robin to lie to the police about the
circumstances of her indoctrination, she fled and eventually returned home.
Less than four months later, Robin‟s father suffered a heart attack, followed by several
strokes, and he died the following September. An expert at trial testified that two years of
anxiety over his daughter aggravated his heart condition and caused him an early death.
Robin and Marcia George became anti-cult activists. On the eve of a Citizens Freedom
Foundation press conference at which the Georges were to speak, the Krishnas put out an
“official statement” concerning Robin claiming she had run away from her parents because
of “cruelty, beatings, harsh treatment.”45
In October 1977, Robin and Marcia George sued the Krishnas for false imprisonment of
Robin, intentional infliction of emotional distress to both, libel to both, and Robin sued for
the wrongful death of her father.
The jury returned a verdict in favor of the Georges on all causes of action and awarded
them in excess of $32.5 million. The Georges accepted a remittitur reducing both punitive
and compensatory damages to a total of $7.9 million.
The tort of false imprisonment derives from the crime of “unlawful violation of the personal
liberty of another”46 and this involves, with one exception, direct physical restraint or the
threat of physical restraint. The exception is when false imprisonment is accomplished by
fraud or deceit.47
The court of appeal found that Robin had not sufficiently established she had been falsely
imprisoned in that 1) there was no proof offered of force or threat of force 2) she was over
14 when enticed to leave home, an age the court found to be “capable of consenting to
conduct that would otherwise be tortious” and 3) she resented no evidence of fraud as to
herself.
Robin sought to distinguish the Molko court‟s finding on false imprisonment as based solely
on protected religious speech, whereas her brainwashing theory involved more than simple
threats of divine retribution. The court determined she had not proved her case, and went
on to describe Molko as
a reaffirmation that physical force or the threat of it is a necessary element of a
false imprisonment cause of action even in the context of a brainwashing claim.
