Eckles v. Sharp

44 Pa. D. & C. 13, 1941 Pa. Dist. & Cnty. Dec. LEXIS 394
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedOctober 21, 1941
Docketno. 3168
StatusPublished

This text of 44 Pa. D. & C. 13 (Eckles v. Sharp) 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
Eckles v. Sharp, 44 Pa. D. & C. 13, 1941 Pa. Dist. & Cnty. Dec. LEXIS 394 (Pa. Super. Ct. 1941).

Opinion

Sloane, J.,

— This is a suit in as-sumpsit by a minor daughter (through her guardian) against her natural father. An affidavit of defense was filed to the statement of claim. Claiming the defense to be insufficient as to amounts admittedly not paid, a rule for judgment was taken, and that rule is what we have before us for solution.

A shorthand account is necessary to a discussion: The father, his now-divorced wife, and her parents, because of “unhappy differences”, agreed in writing: The maternal grandparents were to have “complete cus[14]*14tody” of plaintiff daughter; defendant father was to pay $50 a month for the daughter beginning July 1, 1929; he was to be permitted to visit her at all times, “to take her to see her grandparents [presumably paternal], and also, when she attains the age of nine years, he shall be permitted to take her on trips . . . with the consent” of the custodian grandparents.

Suit was brought for the monthly amounts from December 1, 1929, to the date of this legal action.

It struck us that we ought to decide betimes whether a minor daughter can sue her natural father in contract. She can. Research was burrowing, I suppose because in opinion and text alike the answer, like many an answer in the law, is taken for granted, with virtual unanimity in the conclusion that such an action will lie. See 46 C. J., Parent and Child, pp. 1818, 1324, §§141, 158-159, 4 Vernier, American Family Laws (1936) 480, §267, Madden, Handbook on Law of Persons and Domestic Relations (1931) 409, 442, 1 Schouler, Marriage, Divorce, Separation and Domestic Relations (6th ed., 1921) 716, 717, 2 Williston on Contracts (rev. ed., 1936) 1044,13 Standard Pa. Practice (1939) 320-321, McCurdy, Torts Between Persons in Domestic Relation, 43 Harv. L. Rev. 1030, 1058, 1075 (1930), Steel, Exec., v. Steel, 12 Pa. 64 (1849), Titman’s Administrator v. Titman, 64 Pa. 480 (1870), Kingan’s Estate, 24 Pitts. (O. S.) 41 (1876), Abbott v. Converse, 4 Allen 530, 533 (Mass. 1862), Hall v. Hall, 44 N. H. 293, 296 (1862), and Dunlap v. Dunlap, 84 N. H. 352, 354, 360 (1930). There is considerably greater discussion of the availability of a remedy for torts between parent and child — and the courts are not in accord in their decisions on that question. See McCurdy, Torts Between Persons in Domestic Relation, supra, and Dunlap v. Dunlap, supra. But wherever the matter has been considered, and regardless of whether suit is allowed in tort, it is assumed that access to the courts is not to be denied parent or child for determination between them[15]*15selves of property rights, including contract rights. See Mesite v. Kirchenstein et al., 109 Conn. 77, 145 Atl. 753 (1929), Bulloch v. Bulloch, 45 Ga. App. 1, 163 S. E. 708 (1932), Lusk v. Lusk et al., 113 W. Va. 17, 166 S. E. 538 (1932), and Luster v. Luster, 299 Mass. 480, 13 N. E. (2d) 438 (1938). In Minkin et al. v. Minkin, 336 Pa. 49, 56 (1939), Mr. Justice Stern stated in a concurring opinion:

“I am of opinion . . . that it is not against public policy for a minor to sue his parent, whatever the form of the action, where the suit is to vindicate property rights and not to recover damages for acts of violence or negligence affecting the person.”

The allowance of a suit for vindication of property rights is not to be regarded as an exception to a general rule of nonaccess to the court by a child against his parent.

“There never has been a common-law rule that a child could not sue its parent. It is a misapprehension of the situation to start with that idea, and to treat the suits which have been allowed as exceptions to a general rule. The minor has the same right to redress for wrongs as any other individuals. In the investigation of the subject, the starting point is a general right to demand reparation. The limitations which have been put upon that right have been deduced from prevalent ideas touching family life, and especially parental rights and duties. And here, as one distinguished writer has put it, we ‘are in the realm of belief and emotion.’ 43 Harv. Law Review, 1076. Opposing views have not infrequently been advocated with rhetoric rather than by reason. Out of it all there emerges one substantial and reasonable ground for denying a recovery, and one only. The parental authority should be so far supreme that whatever would unduly impair it should be foregone by the child for his ultimate good”: Peaslee, C. J., in Dunlap v. Dunlap, 84 N. H. 352, 354 (1930).

[16]*16None of the reported cases has imposed limitations of this sort on the minor’s right to sue his parent in contract; and considering the rationale behind such limitations as have been set up by some courts in other types of cases (e. g. torts) we feel that the present suit should be allowed as though it were between strangers.

“As often stated before, the sole debatable excuse advanced for the denial of the child’s right to sue is the effect a suit would have upon discipline and family life. If, therefore, the situation is such that the suit will not affect those matters at all, the reason for the theory fails and it should not be applied”: Dunlap v. Dunlap, supra, p. 367.

If the courts fear that allowing suit in tort would encourage a child, disgruntled by the rightful exercise of discipline, to seek judicial interference in domestic matters which should not be so hampered, it is difficult to see how the allowance of a suit by a child on a contract validly and consciously entered into by his parent would interfere with the parent’s assertion of “discipline”. And especially is this true where the family bond has been severed for some time by divorce of the parents, and adoption of the child by her maternal grandparent as in the instant situation. Defendant father no longer has the proverbial rod which this action might suspend or intersect. The fact that in this particular case the family tie has already been broken is an effective answer to those tribunals which, in denying suits by infants, visualize the determining factor as a desire to avoid friction or disruption of the quietude of the home.

By what we have said we give basis to the assertion that there are no cases denying a child’s right to sue his parent in contract, and that the theory for such denial in tort cases has no application to contract actions in general and to this one in particular. There are cases usually cited as upholding the type of proceeding now before us. They are, to a good extent, actions by a child against the estate of the deceased parent on alleged [17]*17promises of remuneration for support or services rendered: Conrad v. Conrad et al., Admrs., 4 Dall. 130 (Pa. 1793); Neiman v. Gilbert, 1 Woodw. 135 (Pa. 1863) ; Titman’s Administrator v. Titman, 64 Pa. 480 (1870); Abbott v. Converse, supra; Hall v. Hall, supra. The institution of the action occurring after the parent’s death would seem to suggest the non-applicability of the rule since the reasons therefor would no longer exist. But the question before the court, after the parent’s death, would necessarily concern the existence of a cause of action before his demise. If none existed before death, none would arise thereafter. Conversely, allowance of the claims against decedent’s personal representative would be indicative of the recognition that such existed during his lifetime. This is tacitly assumed in most cases, explicitly stated in others. See, for example, Hall v. Hall, supra, at page 296:

“If . . .

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Related

Mesite v. Kirchenstein
145 A. 753 (Supreme Court of Connecticut, 1929)
Greene County v. Southern Surety Co.
141 A. 27 (Supreme Court of Pennsylvania, 1927)
Minkin v. Minkin
7 A.2d 461 (Supreme Court of Pennsylvania, 1938)
Brill v. Brill
127 A. 840 (Supreme Court of Pennsylvania, 1925)
Unverzagt v. Prestera
13 A.2d 46 (Supreme Court of Pennsylvania, 1940)
Crew Levick Co. v. Philadelphia Investment Building & Loan Ass'n
177 A. 498 (Superior Court of Pennsylvania, 1934)
Lusk v. Lusk
166 S.E. 538 (West Virginia Supreme Court, 1932)
Bulloch v. Bulloch
163 S.E. 708 (Court of Appeals of Georgia, 1932)
Steel v. Steel
12 Pa. 64 (Supreme Court of Pennsylvania, 1849)
Titman's Administrator v. Titman
64 Pa. 480 (Supreme Court of Pennsylvania, 1870)
Torrens v. Campbell
74 Pa. 470 (Supreme Court of Pennsylvania, 1874)
Grim v. Thomas Iron Co.
8 A. 595 (Supreme Court of Pennsylvania, 1887)
Andrews v. Blue Ridge Packing Co.
55 A. 1059 (Supreme Court of Pennsylvania, 1903)
Fassitt v. Seip
95 A. 273 (Supreme Court of Pennsylvania, 1915)
Luster v. Luster
13 N.E.2d 438 (Massachusetts Supreme Judicial Court, 1938)

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Bluebook (online)
44 Pa. D. & C. 13, 1941 Pa. Dist. & Cnty. Dec. LEXIS 394, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eckles-v-sharp-pactcomplphilad-1941.