Jefferson v. Jefferson

163 So. 2d 74, 246 La. 1, 1964 La. LEXIS 2469
CourtSupreme Court of Louisiana
DecidedMarch 30, 1964
Docket46871
StatusPublished
Cited by16 cases

This text of 163 So. 2d 74 (Jefferson v. Jefferson) is published on Counsel Stack Legal Research, covering Supreme Court of Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jefferson v. Jefferson, 163 So. 2d 74, 246 La. 1, 1964 La. LEXIS 2469 (La. 1964).

Opinions

SANDERS, Justice.

This is a suit for alimony. Vernita Jefferson, a sixteen-year-old married woman, sued her husband, Limas Jefferson, for alimony for herself and her minor child. She likewise joined as defendants her husband’s parents seeking alimony for the child under Article 229 of the LSA-Civil Code. She alleged in the petition that her husband was a resident of Louisiana, attending college at Baton Rouge, but that he had abandoned her. She further alleged that she appeared as natural tutrix of the child.

An attempt to secure service of citation on the husband failed. He made no appearance in the suit.

The defendant-grandparents filed two exceptions labeled “Exception to the Procedural Capacity”; an exception of no cause of action; an answer to the petition; and, later, an exception entitled “Peremptory Exception — Nonjoinder of Indispensable Party.” The trial court overruled, or otherwise disposed of, the exceptions. After [7]*7trial on the merits, the court rendered judgment in favor of the plaintiff “in behalf of and representing the minor child” against the grandparents for the sum of $20.00 per month as alimony for the child. The grandparents appealed to the Court of Appeal. That court affirmed the judgment.1 We granted certiorari, 244 La. 1026, 156 So.2d 228, to review the judgment of the Court of Appeal.

The exception of no cause of action was apparently referred to the merits without objection. However, the remaining exceptions, directed to the procedural capacity of the mother and to the non-joinder of the father as a plaintiff, have been strongly urged throughout the proceeding.

The first of the exceptions entitled “Exception to the Procedural Capacity” alleges that Vernita Jefferson is under 18 years of age; that her marriage emancipated her for purposes of administration only; and that she has no capacity to sue. The defendants rely upon the provisions of LSA-R.S. 9:102 and LSA-R.S. 9:104.

The objection to the lack of procedural capacity is properly raised by the dilatory exception. Art. 926(6), LSA-C.C.P. However, we find no merit in the objection.

Article 682 of the LSA-Code of Civil Procedure provides:

“A competent major and a competent emancipated minor have the procedural capacity to sue.”

The codal provision makes no distinction between emancipation by marriage and judicial emancipation. Irrespective of the type of emancipation, or its effect, an emancipated minor has the capacity to sue.2

LSA-R.S. 9 :102 provides that married women may appear in judicial proceedings without the authority of their husband or of the judge. LSA-R.S. 9 :104 stipulates that LSA-R.S. 9:102 does not apply to married women who are interdicted or under the age of 18 years. We recognize that LSA-R.S. 9 :104 conflicts in part with Article 682 of the LSA-Code of Civil Procedure. Insofar as a conflict exists, LSA-R.S. 9 :104 must be considered repealed.3

After the trial court had overruled the first exception to procedural capacity, the defendant filed a second exception, likewise labeled “Exception to the Procedural Capacity”, alleging: “That the plaintiff has not been appointed natural tutrix for the minor and has no capacity to bring this suit.” Plaintiff moved to strike this excep[9]*9tion, and the trial court sustained the motion, apparently on the ground that the objection had been waived under Article 926, LSA-C.C.P., by the failure to plead it in the original dilatory exception.

The Court of Appeal held that the foregoing exception was in reality a peremptory exception of no right of action, or want of interest, that it was timely filed and that the objection had not been waived. Finding that the father was an absentee, the Court held that the mother was administratrix of the child’s estate under Article 4502, LSA-Code of Civil Procedure. It overruled the exception.

We cannot agree that the exception raises the objection of no interest in the plaintiff to institute the suit, or no right of action.

It is true, of course, that the character of a pleading is not controlled by its title. Rather, its nature is determined by its purpose and averments.4

As we view it, the present pleading attacks the representative capacity of the plaintiff to sue either as natural tutrix of the minor child, as alleged in the petition, or as administratrix of the child’s estate.

In differentiating the former exceptions of want of capacity and want of interest, Professor Henry G. McMahon, a distinguished authority on civil procedure, stated:

“ * * * [The] exception of want of capacity is deemed the proper and only medium of putting the authority of the plaintiff at issue whenever he appears in a representative capacity, whether as mandatary, tutor, (or for the ‘use and benefit’ of a minor without qualifying as tutor and without facts showing that plaintiff is the administrator of the estate of such minor), curator, administrator, executor, receiver, liquidator, or syndic. This exception appears to be the proper method of putting the procedural capacity of the plaintiff at issue where he appears in an individual capacity, whenever it is contended that for any reason the plaintiff is not sui juris.”5

In our opinion, the present exception challenges the representative capacity of the plaintiff. Prior to the adoption of the Louisiana Code of Civil Procedure, it was characterized as an exception of want of capacity. Under the Code, the objection is one of those raised through the dilatory exception.6

[11]*11The failure of the defendants to plead the objection in the original dilatory-exception waived it. The law does not permit a “stringing out” of dilatory objections in serial pleading. Article 926, LSA-C.C.P., specifically provides:

“All objections which may be raised through the dilatory exception are waived itnless pleaded therein.”

We hold, then, that the objection to the procedural capacity of the plaintiff has been waived. Since the representative capacity was not legally challenged, the qualification of the plaintiff is presumed and no evidence is required to sustain it. Art. 700, LSA-C.C.P.

The exception entitled “Peremptory Exception — Nonjoinder of Indispensable Party” alleges that the plaintiff and her husband are not judicially separated, that the husband is neither incompetent nor an absentee,7 that the husband is the administrator of the child’s estate, that the mother has not been appointed tutrix, and that the husband is an indispensable party plaintiff. The defendants filed the exception on the day of the trial after answer had been filed.

In essence, the exception again challenges the representative capacity of the plaintiff. As we have observed, the objection to the procedural capacity of the plaintiff was waived by failure to plead it in the original dilatory exception. Moreover, the instant objection was pleaded after the answer and is not timely. Art. 928, LSA-C.C.P. Insofar as the exception purports to object to the nonjoinder of the father as plaintiff, it is without merit. The representative capacity of the mother being presumed, all indispensable parties are before the Court.

Having disposed of the exceptions, we consider the merits.

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Jefferson v. Jefferson
163 So. 2d 74 (Supreme Court of Louisiana, 1964)

Cite This Page — Counsel Stack

Bluebook (online)
163 So. 2d 74, 246 La. 1, 1964 La. LEXIS 2469, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jefferson-v-jefferson-la-1964.