Westlake v. Westlake

34 Ohio St. (N.S.) 621
CourtOhio Supreme Court
DecidedDecember 15, 1878
StatusPublished

This text of 34 Ohio St. (N.S.) 621 (Westlake v. Westlake) 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
Westlake v. Westlake, 34 Ohio St. (N.S.) 621 (Ohio 1878).

Opinions

Gilmore, C. J.

The objection, that the original petition does not state facts sufficient to constitute a cause of action raises the question : Can a wife maintain an action, in her own name, for the loss of the society and companionship of her husband, against one who wrongfully induces her husband to abandon or send her away ?

In answering this question, in view of the legislation of our own state on the subject of the rights of married women, it becomes necessary, not only to look to the doctrine of the common law on the subject, but also to examine the reasons upon which its doctrines rest.

In the early period of English jurisprudence, the personal and marital rights of wives were, in some respects, exclusively cognizable in the spiritual courts, and, in other respects, as far as they wrere recognized at all, in the courts of common law.'

[626]*626The common law considers marriage in no other light than a civil contract, some of the incidents of which will be mentioned- hereafter. But the holiness of the matrimonial state is left entirely to the ecclesiastical law; the temporal courts not having to consider unlawful marriage as sinful, but merely as a civil inconvenience. The punishment, therefore, or annulling of incestuous or other unscriptural marriages, is the province of the spiritual courts which act fro salute ánimos. I Black. 432.

The spiritual courts also had cognizance of matrimonial causes or injuries respecting the rights of marriage. Sir W. Blackstone enumerates five of such causes, the third of which is: “ The suit for restitution of conjugal rights, which is brought whenever either the husband or wife is guilty of the injury of subtraction, or lives separate from the other without any sufficient reason, in which case the ecclesiastical jurisdiction will compel them to come together again.” 3 Black. 94. “ In the civil law the husband and wife are considered as two distinct persons, and may have separate estates, contracts, debts, and injuries, and therefore, in our ecclesiastical courts, a woman may sue and be sued without her husband.” 1 Black. 444.

It is unnecessary to inquire into the extent to which a wife could obtain redress for injuries to her personal or martial rights in the spiritual courts. The above quotations are made for the purpose of showing that while it may be doubtful, in view of a recent discussion of the subject, that will be noticed below, whether the common law regards the right of the wife to the consortium of her husband, as of such a nature that pecuniary damages can be given her for being wrongfully deprived of it; yet in a jurisdiction that was exercised concurrently with that of the common law, the x-ights of the wife in these respects were x’ecogixized and x-edressed when injured. The fact, that instead of giving her damages for the loss of .the consortium of her husband, the spii’itual eoui’ts restored to her the thing itself, makes no difference in 'the principle involved. -It -is a distinct recognition of the rights of the [627]*627wife in this respect, by the ecclesiastical law of England, which was founded on the principles of the civil law. But at common law the husband and wife are one person, that is, the very existence of the woman, together with all her personal rights, are suspended during the marriage, or at least are incorporated and consolidated into that of the husband ; and upon this principle, of a union in person in husband and wife, depend almost all the legal rights, duties, and disabilities, that either of them acquire by the marriage. By the marriage, the husband acquires an absolute title to all the personal property of the wife, and a right to reduce her choses in action to possession, and thereby make them his own; also he becomes entitled to her labor and sendees or the proceeds of it, for which latter he may sue in his own name. An injury to the wife is in legal contemplation an injury to the husband only. Eor a slight battery of the wife, the husband may recover damages, but for this he must join his wife in the action. If, however, she is beaten so enormously, that the husband is thereby deprived for any time of her company and assistance, the law then gives him an action in his owii name for this beating, per quod consortium amisit, in which he shall recover a satisfaction in damages. 1 Black. 442; 3 lb. 139, 140.

By comparison the difference between the civil law as administered in the spiritual courts, and the common law as administered in the temporal courts, in respect to the personal and marital rights of the husband and wife, is. plainly apparent. In the former they are regarded as distinct persons, and the wife could have her injuries, of which those courts had jurisdiction, redressed in her own name; while in the latter, they are regarded as one person — the husband, whose name must always be used either jointly with the wife, or alone for the redress of injuries to the person or personal rights of the wife.

If, in this state, the common law dominion of the husband over the property and personal rights of the wife has been taken away from him and conferred upon her, and remedies in accordance with the spirit of the civil law have [628]*628been, expressly given to the wife for the redress of injuries to her person, property, and personal rights, all of which I hope to show has been done, then it must follow that she may maintain an action in her own name for the loss of the consortium of her husband against one who wrongfully deprives her of it, unless the consortium of her husband is not one of her personal rights. It has been already shown that this was one of her ecclesiastical law rights; and I have said that it is doubtful whether it is one of her common-law rights. But before coming to the case in which tb e latter question is discussed, I will recur briefly to the ecclesiastical law. The spiritual courts also had jurisdiction of defamations. In Palmer v. Thorpe, 4 Coke, 19, it is said: “ Touching defamations determinable in the ecclesiastical court, it was resolved that such defamations ought to have three incidents,” the first of which is, “that it concerns matters merely spiritual and determinable in the ecclesiastical court, as for calling him 11 heretic, schismatic, adulterer, fornicator, etc.’ ”

And it was in consequence of such defamations being regarded as matters merely spiritual, of which the spiritual courts had jurisdiction, that the temporal courts held such words as those above quoted not actionable per se; for, if they were actionable in both the spiritual and temporal courts, then a party could be twice punished for the same words. Byron v. Emes, 12 Mod. 106; 2 Salkeld, 694. And here we have the reason why words imputing a want of chastity to a modest matron or a pure virgin, however publicly spoken, were not actionable at common law, without an allegation of special damage.

And here the test question under this rule of the common law may be asked : In an action of slander, brought by a wife, the husband being joined for conformity, will the loss of the consortium of her husband, in consequence of the speaking of slanderous words concerning her, constitute special damage, for which the action will lie ?

This question was very fully discussed and considered in Lynch v. Knight and wife, 9 H. of L. 577. This was an [629]

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Bluebook (online)
34 Ohio St. (N.S.) 621, Counsel Stack Legal Research, https://law.counselstack.com/opinion/westlake-v-westlake-ohio-1878.