Is a smallpox quarantine false imprisonment?
In July of 1911 the board of health in Syracuse New York discovered that a woman living in a house close to Ms. Crayton had smallpox. Pursuant to its powers, the board of health quarantined the house of the infected woman as well as the house of Ms. Crayton on the basis that Ms. Crayton had been exposed to smallpox. The quarantine lasted from July 14 to July 29, 1911. Ms. Crayton brought suit against the officers of the board of health for wrongful imprisonment and other damages for advertising to the town that she had or had been exposed to “a loathsome disease, was unfit to be at large or pursue her occupation, and thereby deprived her of her earnings, injured her feelings, held her up to ridicule, and caused her to be shunned by her fellow citizens.” Her second cause of action was based on the same facts and that the board of health and its agents did “the acts without probable or reasonable cause” and that she had “never had said disease and never had been exposed to said disease.”
