Kenwood v. Tallurigo

31 Ohio N.P. (n.s.) 344
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedDecember 23, 1933
StatusPublished

This text of 31 Ohio N.P. (n.s.) 344 (Kenwood v. Tallurigo) 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
Kenwood v. Tallurigo, 31 Ohio N.P. (n.s.) 344 (Ohio Super. Ct. 1933).

Opinion

Darby, J.

In the first of the above named cases the plaintiff sued to recover for personal injuries; in the second case the action was by the husband of the plaintiff in the first case, for loss of services of his wife and expenses. The defendant denied negligence on his part, and claimed contributory negligence on the part of the wife.

Evidence was offered tending to sustain the issue of both parties in each of the cases.

The court charged the jury to the effect that if it found that the wife were negligent, directly contributing to cause her own injuries, the husband could not recover for the loss of services or expenses.

A general verdict was returned for the defendant in both cases. No special verdict was returned, and it cannot be ascertained now the basis of the jury’s verdicts.

In the motion for new trial in the husband’s case particu[345]*345lar stress is laid upon the claim that the court was in error in charging the jury that if the wife were negligent directly contributing to cause her injuries, the husband could not recover for loss of services, etc.

Counsel for the plaintiff has at great pains, and by great industry, presented a strong argument to support his claim that the contributory negligence of the wife did not affect the right of the husband to recover. Many of the cases referred to by him in his brief are admitted not to directly touch upon the question involved. The general claim, however, is that the Married Woman’s Act by which her so-called “emancipation” resulted, has in some way or other disturbed the general principle of law which seemed to be recognized by the authorities, that where an incidental claim for damages is made the one making the claim cannot recover if the one having the principal cause of action were guilty of contributory negligence.

It would seem that the particular question in this case is settled by the case of Cleve., Col. & Cin. R. R. Co. v. Terry, 8 O. S., 570. The action was brought by Mr. Terry to recover damages for the loss of his wife’s services by reason of.injuries suffered by her while traveling as a passenger of the defendant. The defendant claimed negligence of the wife. The report of the case is quite lengthy, and involves much discussion as to the propriety of charges given and refused. The court, speaking through Peck, J,, however indicated clearly the opinion of the court that the contributory negligence of the wife was a principal matter involved in the case, and if it appeared, that it deprived the husband of his right of action. On p. 580 the court say:

“The issue before the jury involved the question of the exercise of ordinary care and prudence on the part of Mrs. Terry, and also of the railroad officers. * * *”

On p. 581 the court say.:

“Both parties (the railroad company and Mrs. Terry) were bound — the one in running their cars and the other in crossing the track — to the observance of ordinary prudence in order to prevent an injury to either. * * * *
“The jury in this case by their verdict found the defendant below guilty of culpable negligence in the conduct and management of the train, and this would entitle the plain[346]*346tiff below to a verdict and judgment unless Mrs. Terry was also guilty of culpable negligence contributing to the injury.”

The court further discusses this subject of the care required of Mrs. Terry on pages 583 and 584, and all the way through indicates very clearly that her negligence contributing to her injury would defeat her husband’s claim for damages..

It is claimed, however, that that decision was passed before the rule stated in Ohio that the doctrine of imputed negligence does not apply in this state, and it is also claimed that by the Married Woman’s Act referred to this decision has been annulled.

The so-called “imputed negligence” doctrine will be later referred to.

The case of Chicago, B. & Q. R. R. Co. v. Honey, 63 Fed. Rep. (C. C. A.), 39, was a case identical with the one at bar. The syllabus is as follows:

“Notwithstanding the provisions of McClain’s Code of Iowa, Section 3396, that a husband shall not be responsible for civil injuries committed by his wife, and other, provisions enabling a wife to hold property, contract and sue in her own name, a husband in an action for loss of wife’s services occasioned by the negligence of another will be charged with her contributory negligence.”

The court reyersed the decision to the contrary in the Circuit Court. An extended discussion of the question involved is to be found in this case, and the court points out that the rights of the husband to recover for loss of services are incidental to the marriage relation, and are based upon his right to his wife’s services, and to recover for medical attendance in case of sickness or accident. The court say on p. 42:

“The right of action is incident to the marriage relation and cannot exist without it. We think, therefore, that even if it is the better view that the husband’s contributory negligence cannot be imputed to the wife when she sues for her own injuries, yet when the husband brings an action for the loss of society and services which loss was due to the contributory fault of the wife, her want of ordinary care should nevertheless be imputed to the husband on the [347]*347grounds heretofore indicated. As the respective rights of action are predicated on different grounds, the one growing out of the marriage relation and the other existing entirely independent of that relation, there is no logical difficulty in holding the husband accountable for the contributory negligence of the wife, although the latter is not responsible for the contributory fault of her husband.”

The court distinguishes the case of Davis v. Guarinieri, 45 O. S., 470, and an Alabama case of a similar nature, and then states on p. 43:

“We do not see that either of these cases has any marked bearing on the question at issue in the present suit, which concerns the right of the husband to maintain a common law action for the loss of the society and services of his wife when she is shown to have been guilty of culpable negligence which immediately contributed to the injury. In cases of the latter character we are of the opinion that the contributory fault of the wife is a valid defense unless it can be made to appear that the rule of the common law in this respect has been changed by some local statute.”

Reference to the Statutes of Iowa follows, and the conclusion is reached as above set forth.

The nature of the husband’s claim for damage for loss of services of his injured wife is set forth in 13 R. C. L., p. 1412, Section 460 as follows:

“As a general rule a defendant cannot be held liable to a husband for consequential damages resulting to him from an injury to his wife in his loss of her services, etc., unless the defendant would have been liable directly to the wife for the injury to her occasioning the consequential loss to the husband.”

In Jackson v. Boston Elevated Ry., 217 Mass., 515, there were two actions, one for personal injury by the wife, and the other for the consequential damages alleged to have been suffered by the husband of the plaintiff in the first action. On p.

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Bluebook (online)
31 Ohio N.P. (n.s.) 344, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kenwood-v-tallurigo-ohctcomplhamilt-1933.