The confinement need not be in a jail;97 it may be in a private house, or even outdoors, if the party is deprived of freedom of movement.98 Where a person who had been fined for a violation of a municipal ordinance was wrongfully compelled to pay the fine by manual labor on the streets, it was held that there could be a recovery for false imprisonment.99 To constitute false imprisonment, however, the person must be completely deprived of freedom of movement; merely preventing him from going in one direction will not furnish a basis for this action.100

94 9 Lea. (Tenn), 152.

95 35 Ind., 285, Am. Rep., 735.

96 Rich vs. Mrlrney. 103 Ala., 345; State vs. Lunsford, 81 N. Oar.. 528; Amer. & Eng. Ency. of Law, Vol. XII, p. 733.

97 Warner vs. Riddiford, 4 C. B. M.

S., 180. 98 Floyd vs. State, 12 Ark., 43, 54

Am. Dec., 250. 99 Torbett vs. Lynch, 67 Ind., 474.

The imprisonmnet may be accomplished either by force or by threats.101 In case of apprehension by threats, the fear of apprehension which the threats occasion may be either of injury to the person, property, or reputation.102 The threats may be either express verbal threats or may simply consist of acts or gestures.103 The threats must, however, be of such a character as to raise a reasonable apprehension of injury.104