Jurling v. Garner

8 Ohio N.P. 277
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedJuly 1, 1901
StatusPublished

This text of 8 Ohio N.P. 277 (Jurling v. Garner) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jurling v. Garner, 8 Ohio N.P. 277 (Ohio Super. Ct. 1901).

Opinion

Littleford, J.

This action was brought by the plaintiff to recover $1932.00 from the administratrix of his deceased sister, Lizzie Jurling, for board and care rendered by him to his deceased sister for several years preceding her death.

At the close of the plaintiff’s case, the defendant moved to instruct the jury to return a verdict for the defendant, because the plaintiff had failed to establish any contract, either express or implied, between the plaintiff and his deceased sister.

The evidence of the plaintiff showed that Lizzie Jurling, the deceased, who was old and unmarrie'u, came to live with her brother, the plaintiff in this case, about ten years before her death. She was then in good health and she helped with the house-work; but in the course of two or three years, she became ill with consumption and kept growing worse until, during the last few years of her life, she was unable to do any but the very smallest services about the house. She required medical attention -from various doctors, but she paid for the .physicians’ services promptly out of her own means. The family gave her the best room in the house and prepared special dishes for her, besides giving her egg-nog, brandy and wine. The house in which she lived was a saloon and boarding-house belonging to her brother, the plaintiff, but at no time during her stay there did her brother ask her for board nor did she at any time offer to pay board. She was a good tempered old woman and was always treated like a member of the family. After introduciug evidence to establish this slate of facts, the plaintiff rested.

The point made by counsel for defendant on the motion to instruct the jury to bring in a verdict for the defendant is, that although the facts shown by the plaintiff might be sufficient to establish a case of implied contract had the plaintiff and deceased been strangers to each other, still in a case like this, where they were brother and sister, the plaintiff must go further and assume the burden of establishing that there was either an express or implied contract by which the deceased was bound to pay for the services rendered to her in giving her board and care.

If the fact that the plaintiff and deceased were brother and sister is of no moment in the premises, and in the eyes of the law they were the same as strangers, as counsel for plaintiff maintain, then what the plaintiff must show to make out a prima facie case has already been decided in Ohio in the case of Harrison v. Gotleib, 3 C. C., 191. That case, decided by Smith, C. J., of Hamilton County Circuit Court holds as follows:

“Where services have been rendered by one person to another with his knowledge, but wi.kont any express contract between them, this of itself is not sufficient to entitle the person so rendering the service to recover therefor as on an implied contract. ‘Implied contracts are those which reason and justice dictate, and which therefore the law presumes that every man undertakes to perform.’ It should therefore further appear from the circumstances of the case, that the services rendered were such as people as a rule expect to be paid for'; and then, if there are no special circumstances to show that they were rendered gratuitously, or that the person availing himself of them, honestly believed, and had reason to believe, that they were so rendered, the promise to pay the value thereof may reasonably be inferred.”

According to this decision, the burden would be upon the defendant to establish that there was no implied contract in a case like the one in hand if the parties were strangers to each other; and the question is whether the relationship of brother and sister between the plaintiff and the deceased changes the rule as to the burden of proof.

There have been several cases in Ohio which hold that a child or step-child residing with a parent or step-parent as a member of the family cannot recover for' services rendered to the parent in the absence of an express promise to pay therefor or of facts and circumstances which amount to an implied promise. See Hawthorn v. McClure, 4 C. C., 11; Pollack v. [278]*278Pollack, 2 C. C., 143; Lovet v. Price, Wright, 89; and Willis v. Dunn, Wright, 134.

In addition to these cases, there is a case holding that where sisters live together in the same family, one cannot recover for services rendered to the other in the absence of an express contract. In re estate Catharine Dunn, Goebel’s Probate Reports, 297. This case, however, was carried on appeal to the Common Pleas Court and' the decision was there reversed, the court holding that a sister could recover for services rendered to a sister where such services “are to be classed with necessaries and were in no sense voluntary”, the law in such case implying a contract to pay.

Going outside of the state for authorities, we find in the case of Scully v. Scully’s executor, et al., 28 Ia., 548, an action brought by the sister of decedent, the following laid down in the text of the decision:

“Ordin'arily and without more, where one person renders services for another which are known to and expected of him, the law implies a promise on his part to pay therefor. But where it is shown that the person rendering the services is a member of the family of the person served and receiving support therein, either as a child an ■ relative or a visitor, a presumption of law arises that such services were gratuitous; and in such case before the person rendering the services can recover, the express promise of the party served must be shown or such facts and circumstances as will authorize the jury to find that the services were rendered in the expectation by one, of receiving, and of ■ the other of making, compensation therefor,”

Again in the case of Hall v. Finch, Ad’m’r. 29 Wis., 278, a case brought by a sister against the estate of her deceased brother, it is held, after a careful consideration of numerous authorities, as follows:

“The relationship of parent and child, stepparent and step-child, and brother and sister, or the like, existing between persons living together in the same household creates a strong presumption that no payment or compensation was intended to be made for services rendered by one to the other beyond that received at the time they were rendered. The person claiming pay for services in such a case must overcome such presumption by clear, direct and positive proof that the relation between the parties was not merely the ordinary one of parent and child or brother and sister, but that of debtor and creditor, or servant and master; and must show some arrangement or contract to that effect.”

It is not necessary to determine here whether “clear, direct and positive proof” would be necessary in Ohio to overcome this presumption, but the case nevertheless supports the theory that the burden of proving the contract is on the plaintiff in such case.

In the case of Fuller v. Fuller’s Estate, 21 Ind. App., 42 (1898), a case in which the facts are quite like the facts here, the syllabus is as follows:

“Plaintiff filed a claim against his sister’s estate for board and care. The evidence showed that she lived with him from the lime she was a child until her death at the age of twenty-eight years; that plaintiff’s family was large an < the sister was treated as a member of the family and assisted with the house-work. There was no agreement to receive pay for her services nor to pay for board and care received by her.

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Related

Hall v. Finch
29 Wis. 278 (Wisconsin Supreme Court, 1871)
Fuller v. Fuller's Estate
51 N.E. 373 (Indiana Court of Appeals, 1898)
Scully v. Scully's
28 Iowa 548 (Supreme Court of Iowa, 1870)

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Bluebook (online)
8 Ohio N.P. 277, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jurling-v-garner-ohctcomplhamilt-1901.