In People v. Checketts (1999) 71 Cal.App.4th 1190, the defendant was convicted of false imprisonment after he beat his daughter and ordered her to go into the attic and remain there for a couple of days so the social worker would not see her injuries. (71 Cal.App.4th at p. 1193.) On appeal, he argued that he could not be convicted of false imprisonment because, as a parent, he has a right to control his own child. The court rejected this argument holding that "a parent is not immune from criminal prosecution for false imprisonment of his child where the act of confinement is done with an intent to endanger the health and safety of the child, or to achieve an unlawful purpose, because such an act exceeds the scope of parental authority." (Id. at p. 1192.)In that case, the father, who was charged with the false imprisonment of his daughter, challenged his conviction on the basis that he had the right to detain his child at any location for any reason. The evidence showed that, after the father subjected his daughter to a severe beating, he forced her to hide in the attic for a couple of days to prevent the social worker from discovering her injuries. The father argued that he was immune from prosecution for false imprisonment based on his parental right to reasonably discipline his daughter, including the right to confine her to a particular location for disciplinary reasons. In rejecting the father's argument in Checketts, this court noted that not all parental acts of discipline are lawful. (Checketts, supra, 71 Cal.App.4th at p. 1194.) A parent is subject to criminal prosecution when the parent oversteps his legal authority and exercises his parental rights for an unlawful purpose. (Id. at p. 1195, citing People v. Senior (1992) 3 Cal.App.4th 765 and People v. Rios (1986) 177 Cal. App. 3d 445, 222 Cal. Rptr. 913.) The Court concluded that, when a parent acts with the intent to endanger or injure his child, his actions are patently in excess of his parental authority. (Checketts, supra, at p. 1195.) In such cases, the parent is not immune from criminal prosecution, including prosecution for false imprisonment. (Ibid.) In Checketts, the Court also addressed whether, during the trial for false imprisonment, the trial court had a duty to instruct the jury on the father's right to reasonably detain his child. (Checketts, supra, 71 Cal.App.4th at p. 1197.) The Court observed that, despite father's claim that his confinement of his daughter was a reasonable exercise of parental authority, there was no evidence in the record to support his claim. (Ibid.) Instead, the evidence showed that defendant acted with an unlawful purpose, i.e., to avoid prosecution for beating his daughter. (Ibid.) The trial court, therefore, had no sua sponte duty to give the instruction. (Ibid.)