Bentel v. Strickler

8 Pa. D. & C. 768, 1926 Pa. Dist. & Cnty. Dec. LEXIS 189
CourtPennsylvania Court of Common Pleas, Beaver County
DecidedAugust 20, 1926
DocketNo. 507
StatusPublished

This text of 8 Pa. D. & C. 768 (Bentel v. Strickler) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Beaver County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bentel v. Strickler, 8 Pa. D. & C. 768, 1926 Pa. Dist. & Cnty. Dec. LEXIS 189 (Pa. Super. Ct. 1926).

Opinion

Reader, P. J.,

— On Feb. 6, 1926, the plaintiff’s statement of claim was filed in the above entitled case, and on March 6, 1926, an affidavit of defence was filed raising questions of law. Sometime later the matter was argued before the court.

Substantially the questions of law raised are, that while the action is brought against the defendants jointly, no joint liability of the defendants is disclosed by the statement, but, on the contrary, any liability of the defendants disclosed is several; and, further, that it appears from the face of the statement that at the time of the accident which is the foundation of the action, the car was being driven by the defendant, Floyd M. Strickler, without any participation therein by the other defendant, his wife, Anna M. Strickler.

[769]*769Upon the argument of the ease, it was contended that under the statement of claim there could be no liability of the wife, Anna M. Strickler, because of the legal presumption that any tort committed by her in the presence of her husband was committed at his direction, and was his tort and not hers. The principle relied upon is thus stated in the case of Wheeler & Wilson Manuf. Co. v. Heil et al., 115 Pa. 487: “When a tort is committed by a wife, she is personally liable, unless her husband is both present and directs the doing of it at the time: Franklin’s Appeal, 18 W. N. C. 245. His presence furnishes evidence and raises a presumption of his direction, but it is not conclusive, and the truth may be established by competent evidence: Cassin v. Delany, 38 N. Y. 178. ‘The true view is, when the husband is present during the commission of a tort by the wife, whether himself actively participating in it or not, prima fade, the wrong shall be deemed his alone; but both in civil and criminal causes this prima fade case may be rebutted, and each of the two may be deemed in law the doer of the wrong, the same as though they were unmarried:’ Cord on Rights of Married Women, 1154.”

The rule is similarly stated in the case of Hess v. Heft, 3 Pa. Superior Ct. 582: “The liability of the defendant for wrong here complained of is to be tested by certain well settled principles. At common law, the husband was liable for the torts of his wife, whether committed before or during coverture. For a tort in which the wife took an independent part, the husband and wife were jointly liable. For a tort which she committed by his direction, he alone was liable. The wife being sub potestate viri, if she committed a tort in the husband’s presence, it was presumptively in obedience to his direction; and, unless it appeared that she acted wholly of her own will, he alone was liable: 2 Kent, 149; Quick v. Miller, 103 Pa. 67; Franklin’s Appeal, 115 Pa. 534; Wheeler & Wilson Manuf. Co. v. Heil, 115 Pa. 487.” See, also, Deardorff v. Pepple, 36 Pa. Superior Ct. 224.

The independent liability of the wife for her own torts generally is now much more clearly recognized than it seems to have been at the time when the decisions above cited were made. Thus, in the ease of Smith v. Machesney, 238 Pa. 538, the court said: “The husband seems to have been joined as a defendant in this case under the idea that the common law liability of the husband for the torts of the wife still prevails. But whatever may have been the rule at common law, we held in Gustine v. Westenberger, 224 Pa. 455, 460: ‘Since the passage of the Act of June 8, 1893, P. L. 344, a married woman may be sued civilly in all respects and in any form of action with the same effect and results and consequences as an unmarried person, except that she may not be arrested or imprisoned for her torts. Under that act, she, and not her husband, is liable in damages for her torts.’ In the present case it was, therefore, not only unnecessary, but improper, to join the husband as a defendant. We do not understand that the claim in this case was made against the husband as an actual tortfeasor, but only by reason of his supposed responsibility for the tort of his wife.”

It is true that in this case the alleged tort of the wife consisted in negligence in the maintenance of a freight elevator upon property owned by her, and was not a tort committed in the presence of her husband. The case, nevertheless, recognizes that under existing statutes relating to the rights and liabilities of married women the liability of a married woman for her tort must be borne by her and is visited upon the husband only in exceptional cases. The rule stated in the case last cited is recognized in the case of Crouse v. Lubin, 260 Pa. 329, where the wife was held liable for damages resulting from the negligent operation of an automobile owned by her, used for [770]*770family purposes, and particularly for the use of her mother, and at the time of the accident being driven by a chauffeur for the accommodation of the owner’s mother. The rule was again applied in the case of Hinski v. Stein, 68 Pa. Superior Ct. 441, an action of slander. A number of cases in which the rule is considered are collected in 20 Am. Law Reps., note on page' 528 (538).

In the instant case the statement avers that at the time of the accident in question the defendants were owners of one Overland de luxe sedan automobile. The rules of law recognize the right of the wife to own and possess property, both real and personal, jointly with her husband, the title in our State being’ treated as a title by entireties. The right of either to use the property, ór of both to use it in common for their common purposes, is also recognized by the law. It seems to us that in a case of common use of such property by the husband and wife for a purpose common to both, there would arise a common liability for negligence incident to such common use of it.

The presumption arising from the presence of the husband at the time of the commission of a tort by the wife that she acts under his direction, and that the tort is his only, is prima fade only, and, as stated in the case of Wheeler & Wilson Manuf. Co. v. Heil, above cited, as well as in the other cases in which the rule is recognized, “may be rebutted and each of the two may be deemed in law the doer of the wrong, the same as though they were unmarried.” It seems to us, in view of the present status of married persons under our statutes and the construction thereof by more recent decisions, such as we have above quoted, that where property is shown to be that of both husband and wife, and that the negligence complained of in the use of that property arises from a common use of it by both owners for the common purpose of both, a case of liability is stated against both, and the presumption of the sole liability of the husband is negatived.

If the averments of the statement in the instant case were such as we have just defined, we think the statement would present a legal claim against the defendants. The substantial statements in the plaintiff’s statement of claim following the statement of ownership above referred to, so far as they relate to the liability of the defendants or either of them, are in substance as follows : In the 7th paragraph of the statement it is said:

“7. That defendants’ car approached the car in which the plaintiff was riding, immediately prior to the accident aforesaid, in an easterly direction, and the defendant, Floyd M.

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Related

Cassin v. . Delany
38 N.Y. 178 (New York Court of Appeals, 1868)
Laubach v. Colley
129 A. 88 (Supreme Court of Pennsylvania, 1925)
Felski v. Zeidman
126 A. 794 (Supreme Court of Pennsylvania, 1924)
Quick v. Miller
103 Pa. 67 (Supreme Court of Pennsylvania, 1883)
Wheeler & Wilson Manufacturing Co. v. Heil
8 A. 616 (Supreme Court of Pennsylvania, 1887)
Appeal of Franklin's Administrator
6 A. 70 (Supreme Court of Pennsylvania, 1886)
Lotz v. Hanlon
66 A. 525 (Supreme Court of Pennsylvania, 1907)
Gustine v. Westenberger
73 A. 913 (Supreme Court of Pennsylvania, 1909)
Smith v. Machesney
86 A. 493 (Supreme Court of Pennsylvania, 1913)
Crouse v. Lubin
103 A. 725 (Supreme Court of Pennsylvania, 1918)
Farbo v. Caskey
116 A. 543 (Supreme Court of Pennsylvania, 1922)
Markle v. Perot
116 A. 542 (Supreme Court of Pennsylvania, 1922)
Sieber v. Russ Bros. Ice Cream Co.
120 A. 272 (Supreme Court of Pennsylvania, 1923)
Gojkovic v. Wageley
123 A. 466 (Supreme Court of Pennsylvania, 1924)
Hess v. Heft
3 Pa. Super. 582 (Superior Court of Pennsylvania, 1897)
Deardorff v. Pepple
36 Pa. Super. 224 (Superior Court of Pennsylvania, 1908)
Hinski v. Stein
68 Pa. Super. 441 (Superior Court of Pennsylvania, 1917)

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Bluebook (online)
8 Pa. D. & C. 768, 1926 Pa. Dist. & Cnty. Dec. LEXIS 189, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bentel-v-strickler-pactcomplbeaver-1926.