Phillips v. Graves

20 Ohio St. (N.S.) 371
CourtOhio Supreme Court
DecidedDecember 15, 1870
StatusPublished

This text of 20 Ohio St. (N.S.) 371 (Phillips v. Graves) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phillips v. Graves, 20 Ohio St. (N.S.) 371 (Ohio 1870).

Opinion

McIlvaine, J.

This action is prosecuted by the plaintiffs-against the defendants, Benjamin Graves and Elizabeth B.,. his wife, for the purpose of charging the separate estate of the wife with the payment of a claim for the price and value-of a piano-forte sold and delivered by the plaintiffs to her on the 18th day of April, 1866, for which she executed to them a written instrument, as follows :

“.$510.. Received of Philip Phillips & Co., a No. 4 Bradbury piano, valued at five hundred and ten dollars, to be paid for by the 20th day of May, 1866.
“E. B. Graves.”
“New Carlisle, Ohio, April 18, 1866.”’

The allegations of the petition are in substance as follows t

1st. The coverture of said defendant Elizabeth, at the time of sale.

[379]*3792d. That she then was, and still is, the owner of a larga estate of real and personal property, and ehoses in action, of great value, to wit: nineteen thousand dollars and more, which is under her sole control and exclusive management and which she owns in fee-simple, in her own right, and as her own separate property, and from which she annually receives, for her own separate use, an income of more than $1,000.

3d. That the defendant Benjamin Graves, husband of said Elizabeth, at the time of said sale, had no property, nor is he-now possessed of any property, of any kind, subject to levy and sale on execution, or otherwise, for the payment of debts.

4th. That said Benjamin acquiesces in, and consents to, the-acts of management, control, and disposition, by said Elizabeth, of her separate property.

5th. That said piano-forte was purchased by said Elizabeth for her own benefit and for her separate use and property.

6th. That, at the time of the sale of said piano-forte, it was agreed and understood by and between said plaintiffs and said Elizabeth, that the same was sold upon the credit of her separate property, and that she intended to and did charge her separate estate and income with the payment thereof.

7th. That said claim is due, and that said defendants have-neglected and refused to pay the same.

And the plaintiffs, having specifically described, in the-petition, the separate property of said Elizabeth, pray for an-account, etc., and that the amount found due them may be-charged upon the separate estate and income of said Elizabeth, and for other and further relief, etc.

Defendants demurred to the petition on the ground that it did not state facts sufficient to constitute a cause of action.

This demurrer was sustained by the court of common pleas, and final judgment was rendered in favor of defendants.

From this judgment an appeal was taken to the district court and the case was therein reserved for decision here.

The ease now stands upon general demurrer to the petition..

[380]*380By the.rules of the common law, married women are placed under many and severe disabilities, both as to their personal :and property rights, intended, according to a favorite maxim, “ in the most part for their protection.”

Whatever may be' the reason of the law, the rule is maintained, “ that the legal existence of the wife is merged in that ■of the husband, so that, in law, the husband and wife are one person.”

The husband’s dominion over the person and property ox the wife is fully recognized. She is utterly incompetent to •contract in her own name. He is entitled to her society and her service; to her obedience and her property. All her personal chattels are absolutely his, and her choses in action when reduced to his possession, and the right to so reduce them his will and pleasure. He has an unqualified right to the use of her realty during coverture, and an estate for life, in the event of her death, if she bear him a child born alive, etc.

In consideration of his marital rights the husband is bound to furnish the wife a home and suitable support. He owes her protection, and is liable for her debts contracted before marriage.

Such is a brief but general outline of a married woman’s legal status, as declared and enforced in commonl-aw couxbs.

Courts of equity, however, do not fully adopt the theory, nor follow the practice of combs of law, in relation to the rights and responsibilities of husbands and wives, as between themselves, or in their relation to others.

A fundamental distinction exists at the very threshold of their jurisprudence. Equity recognizes the separate existence of the wife, and regards her as a rational and responsible subject •of its jurisdiction; entitled to its protection and amenable to the decrees of a court of conscience.

At an early period in the history of equity jurisprudence, a married woman was considered capable of possessing property for her own use. For the protection of her natural rights and to enable her to discharge her moral obligations, equity devised for her a separate estate over which the husband was not permitted to exercise his dominion. This estate, [381]*381at first, was created by deed of settlement to trustees for her sole use and. benefit, over which courts of equity exercised jurisdiction to the exclusion of courts of law. A power of appointment in favor of the wife was inserted in the deed,, and the trustees for her benefit were compelled to fulfil her appointments. Both real and personal property were embraced in this new creation.

In the progress of time, courts of equity dispensed with the-necessity of the power of appointment, and held that the jus(MsjoonenM was a necessary incident to the ownership of property — as well the separate property of married women as-other property.

At length the intervention of trustees was held to be-unnecessary, and equity recognized the capacity of a married woman to take a direct grant for her separate use.

This principle was gradually developed until it became-fully settled, “that however a wife’s property might be acquired, whether through contract with her husband before-marriage, or by gift from him, or from a stranger independently of such contract, equity would protect it, if duly set apart as her separate property, no matter though the husband himself must be held as the trustee to support it.” Schouler’s • Dom. Rel. 188.

This great change in the condition of married women was wrought without the aid of legislation. Courts of chancery in this, as in many other respects, recognized their own true-function of making their rules work justice by accommodating their operation to the true relations of society.

Thus a strange anomaly exists in English and American-jurisprudence. Courts of law and courts of equity co-existent in the same realm — the former merging the legal existence-of the wife in the husband — the latter recognizing her separate existence — the former declaring her incapable of acquiring, holding, or disposing of property — the latter recognizing her ability to acquire, control and dispose of her estate — the former denying her capacity to contract, or to sue-- or be sued — the latter enforcing her agreements by granting-relief both for and against her 1

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Bluebook (online)
20 Ohio St. (N.S.) 371, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillips-v-graves-ohio-1870.