Commonwealth ex rel. Howell v. Howell

26 Pa. D. & C.2d 22, 1961 Pa. Dist. & Cnty. Dec. LEXIS 34
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedDecember 4, 1961
Docketno. 137,468
StatusPublished

This text of 26 Pa. D. & C.2d 22 (Commonwealth ex rel. Howell v. Howell) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth ex rel. Howell v. Howell, 26 Pa. D. & C.2d 22, 1961 Pa. Dist. & Cnty. Dec. LEXIS 34 (Pa. Super. Ct. 1961).

Opinion

Stout, J.,

The question for answer is whether, in the circumstances of this case, it was an abuse of discretion to order a father to pay college tuition for an 18-year-old daughter from the proceeds of an insurance policy he maintained for that purpose. The question of her day-to-day support is not involved in this appeal.1

The father, a graduate of Temple University School of Pharmacy, is registered and practicing as a pharmacist in a business he has owned and operated over 20 years. The mother is a college graduate who [24]*24majored in secretarial education at Hampton Institute in Virginia. They were married June 10, 1938. The daughter, their only child, was born September 10, 1943. She graduated from Girls High School in June 1961, in the fourth quintile of a class of 221 students. On June 19, 1961, she was admitted to Temple Community College for the secretarial course which began around September 21, 1961.

Approximately 10 years ago, the father, in the presence of the mother, entered into a contract of insurance with the North Carolina Mutual Insurance Company for the purpose of establishing a fund to defray expenses of the daughter’s college education. The policy was maintained throughout the years for that purpose and has a present value of upwards of $1,000.2 The tuition at Temple Community College for the course the daughter wishes to pursue is either $440 or $540 per term. Even though the policy was available, and the father stated in open court on August 1st, that he was not only interested in his daughter’s securing higher education but that, on the question of tuition, there was nothing to worry about as the tuition would be paid, when it became payable in September, he refused to honor his representation. He gave as his reasons that the daughter had reached her eighteenth birthday a few days before on September 10, 1961, and had completed high school, that there was nothing to indicate she was either physically or mentally unable to support herself, and that he owed no duty to support her while she attended college.

The fact that a child has reached the eighteenth birthday does not relieve the father of the duty to sup[25]*25port. At common law, that duty continued until the child reached the age of 21, and thereafter in case of disability: Mt. Pleasant Overseers v. Wilcox, 2 Dist. R. 628 (1893). The statutory duty imposed by this Commonwealth is no less. The word “children” in the nonsupport statute3 is used to denote persons under 21 years of age (Commonwealth ex rel. O’Malley v. O’Malley, 105 Pa. Superior Ct. 232, 161 Atl. 883 (1932)) as distinguished from the ordinary meaning of the word as male or female descendants in the first degree, of whatever age. It bespeaks minority rather than adulthood, dependence rather than independence, unemancipation rather than emancipation. Whether the duty to support continues beyond age 21 depends on whether the adult child is physically and mentally able to engage in profitable employment, and whether employment is available to him or her at a supporting wage: Commonwealth ex rel. Groff v. Groff, 173 Pa. Superior Ct. 535, 98 A. 2d 449 (1953). The extent of the duty to support before age 21 is a different question entirely.

Even though the common law as well as the statutory duty extends to age 21, by practice, and by practice only, in some counties, it has been terminated at an earlier age upon proof that the child was self-supporting.4 In Commonwealth v. Gilmore, 97 Pa. Superior Ct. 303 (1929), the court said:

“In this county, [Berks] ... it has been our invari[26]*26able practice under this statute to revoke all orders for support of normal children upon their reaching the age of 16 years. But by inquiry among the judges of the courts of many other counties in the state we have learned that their practice is different. In general the usual practice in this Commonwealth seems to be to continue the order during minority or until the child is in fact at work and self-supporting, subject, of course, to a prior revocation where the child though in school, is wasting his time or is incapable of further progress. In other words, the courts do not, in the ordinary case, interfere with the child’s wish to get a common-school education but require the father, if able, to provide for the child during such time, having regard, however, to the child’s ability and progress.”

And see Fusco Estate^ 16 D'. & C. 2d 129 (1958), where President Judge Reed, in speaking of allowances from an estate, stated that while Beaver County had no established rule, it had been their policy and practice to follow the rule of Allegheny County that, beyond high school grades, no allowance would be made for educational purposes for a person for more than one year.

The appellate and lower courts of this State, and of others, have examined frequently circumstances under which support and/or tuition payments for college students, even those over 21, may be enforced against fathers. Obviously, all fathers in all circumstances are not required to support, and/or pay tuition for all children to go to college. That does not negative the fact that some fathers, in some circumstances, are required to pay support and/or tuition for some children to attend college. Each case must be decided on its own facts.5 We think, to the extent of the fund [27]*27created by the insurance maintained for the purpose of the college education of the daughter, this is such a case.

Most of the cases decided in Pennsylvania have involved the construction of written agreements.6 In Wiegand v. Wiegand, 349 Pa. 517, 37 A. 2d 492, defendant, by separation agreement, undertook to pay for four-year college courses for his children even though the courses would not be completed during the minority of each child. As against his contention that after his student son reached majority, he was liable for fees and tuition only and not for support and maintenance, the court said:

“The defendant intends to cover the maintenance of his son for four years in college and the expenses incident thereto. For a man of humble circumstances, it might have meant only books and tuition; but this defendant is a man of large means and would intend to maintain his son as other men of like standing maintain their sons in college, which would cover the cost of board and room, books, and the like, as well as tuition, matriculation and laboratory fees”: 349 Pa. at 522, 37 A. 2d at 495. (Italics supplied.)

Commonwealth ex rel. Grossman v. Grossman, 188 Pa. Superior Ct. 236, 146 A. 2d 315 (1958), also in[28]*28volved the construction of a separation agreement by which the husband, a dentist, agreed, when his son was 12% years old, to pay for his support until he “completed his schooling.” In construing this agreement, the lower court found that it was “within the contemplation of the parties that the father should pay for his son’s support while he was attending college or until such reasonable time as his schooling would be completed or terminated.” In affirming the order, the Superior Court said:

“. . . if we are to ascribe reasonable, probable and natural conduct to a professional man, we must conclude that it was the father’s intention when he signed the agreement to help his son through college”: 188 Pa. Superior Ct. at 241.

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Bluebook (online)
26 Pa. D. & C.2d 22, 1961 Pa. Dist. & Cnty. Dec. LEXIS 34, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-ex-rel-howell-v-howell-pactcomplphilad-1961.