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DOE v. MAHARISHI MAHESH YOGI

December 9, 1986

JOHN DOE, Plaintiff,
v.
MAHARISHI MAHESH YOGI, ET AL., Defendants



The opinion of the court was delivered by: GASCH

 OLIVER GASCH, Judge

 I. FACTS

 In September of 1985, seven plaintiffs, John Does I thru VI and Jane Doe, *fn1" filed a complaint requesting relief for injuries related to their practice of transcendental meditation ("TM"), the "Science of Creative Intelligence," and "Sidhis." *fn2" The parties which the plaintiffs claimed were responsible for their injuries are the Maharishi Mahesh Yogi ("Yogi"), the founder and spiritual leader of TM, the World Plan Executive Council, a nonprofit corporation that conducts business for the Yogi in the United States; and the Maharishi International University in Fairfield, Iowa, which provides courses of instruction in meditation and self-realization techniques purportedly developed by the Yogi. *fn3"

 In reliance on these representations, the plaintiff paid for a number of courses taught by the defendants. The plaintiff claims to have spent eleven years attempting to realize the benefits promised by the defendants. The plaintiff claims to have passed four of these years working full-time for the Yogi and his organization for little or no pay.

 The plaintiff claims that as a consequence of enrolling in the Yogi's courses, he became dependent on the defendants. The plaintiff states that fear and intimidation were used by the Yogi to prevent him from discontinuing his involvement with TM, alienating him from his family and friends outside the TM milieu. The plaintiff asserts that these techniques resulted in, inter alia, severe emotional distress, lasting psychological injury, and, in the case of Sidhis, physical injury as a result of attempts to "fly."

 John Doe I's complaint alleges fraud, negligence, breach of warranty *fn4" and intentional infliction of emotional distress. He claims that punitive damages are appropriate and requests redress in the amount of $9 million.

 The defendants claim that summary judgment is appropriate to dispose of all of the plaintiff's claims.

 II. DISCUSSION

 A. Standards Governing Motions for Summary Judgment

 Rule 56 of the Federal Rules of Civil Procedure states the standard upon which all motions for summary judgment must be reviewed. The rule states, in pertinent part,

 
The judgment sought shall be rendered forthwith if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.

 Fed. R. Civ. P. 56(c). This rule clearly embodies the black letter principle that summary judgment is appropriate when there is no genuine issue of material fact. See Adickes v. S.H. Kress & Co., 398 U.S. 144, 153, 26 L. Ed. 2d 142, 90 S. Ct. 1598 (1970). The moving party bears the initial burden of demonstrating the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 106 S. Ct. 2548, 2553, 91 L. Ed. 2d 265 (1986). If the moving party can demonstrate that no material facts are in dispute, it becomes the obligation of the party opposing the motion to prove that a material fact is in dispute. See Greenberg v. FDA, 803 F.2d 1213 (D.C. Cir. 1986).

 In Celotex, the Supreme Court held that summary judgment is an integral component of the federal rules, not merely a "procedural shortcut." Celotex Corp., supra, 106 S. Ct. at 2555. Nonetheless, the Court recognized in a companion case that courts should act with "caution" when granting such motions. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 106 S. Ct. 2505, 2514, 91 L. Ed. 2d 202 (1986). Although this language indicates that the Supreme Court favors summary judgment in proper cases, in a subsequent decision, the United States Court of Appeals for the District of Columbia Circuit held that summary judgment is a "drastic remedy." See Greenberg, supra, at slip op. p. 5. The Court understands these cases to stand for the proposition that summary judgment should only be granted in clear cases.

 To assure that no person is deprived of his or her day in court, "the inferences to be drawn from the underlying facts contained in such materials [affidavits, depositions, and exhibits] must be viewed in the light most favorable to the party opposing the motion." Anderson, supra, 106 S. Ct. at 2513. In furtherance of this end, a trial court should not deny summary judgment where it believes that the better course is to proceed to trial. Id. When determining whether a reasonable jury could find for the ...


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