Zilley v. Dunwiddie

40 L.R.A. 579, 74 N.W. 126, 98 Wis. 428, 1898 Wisc. LEXIS 155
CourtWisconsin Supreme Court
DecidedFebruary 8, 1898
StatusPublished
Cited by37 cases

This text of 40 L.R.A. 579 (Zilley v. Dunwiddie) is published on Counsel Stack Legal Research, covering Wisconsin Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zilley v. Dunwiddie, 40 L.R.A. 579, 74 N.W. 126, 98 Wis. 428, 1898 Wisc. LEXIS 155 (Wis. 1898).

Opinions

PiNNEY, J.

At the common law the husband was primarily liable for the support of his minor children. 2 Kent, Comm. 190. In McGoon v. Irvin, 1 Pin. 532, it was said that “ by every principle of law upon the subject, recognized and strengthened by our statute, parents are under legal obligation to maintain and support their children who are of tender years and helpless.” The statute (K. S. 1878, sec. 1503) makes the father primarily liable to support his minor children. When the marriage is dissolved by divorce, the duty of parents to maintain their children remains as before, for children are not parties- to the divorce suit and do not lose any rights thereby. Hence the father’s duty to maintain them after the divorce, where there is no decree of the court relating thereto, especially if their custody is not [433]*433taken from him, remains as before. After the parents were divorced all duties and obligations to each other- ceased, and they became as strangers to each other. Nelson, Div. & Sep. § 981. The claimant owed the husband no duty as ivife, and her duty to support the child continued, as before, secondary, and his primary. 2 Bishop, Mar., Div. & Sep. § 1210; Plaster v. Plaster, 47 Ill. 292. It is generally laid down that the liability of the husband to a divorced wife, in respect to the support of the children, is the same as to any other third person, except as provided in the decree. If the court makes no order either for custody or support of children of the marriage, the divorce leaves the father’s liability as at common laAv, and the mere divorce does not terminate his liability. 2 Bishop, Mar., Div. & Sep. § 1220; Thomas v. Thomas, 41 Wis. 233. In a proper case, it seems, after the marriage is dissolved, he may be answerable to the mother for maintenance rendered the children while living with her. Stanton v. Willson, 3 Day, 37; Buckminster v. Buckminster, 38 Vt. 248. The father is under legal obligation to provide for the support of his children, even if they remain with their mother after her divorce, and, as against the public and the children, he cannot escape the duty. Courtright v. Courtright, 40 Mich. 633. Where the decree has granted the custody of the children to the wife and contains no provision for their support, it has been held that the father is not liable for the support of the children. But this is upon the ground that, the statute having made it the duty of the court to provide for their custody and maintenance upon divorce, it will be presumed that the decree has made all the provisions on that subject that ivere necessary; that the decree is conclusive as to the respective rights and obligations of the parties, subject to the right to have it modified as subsequent exigencies may require. As the decree makes the parties strangers as to each other, it is generally considered that a divorced husband is not liable [434]*434to his divorced wife for necessaries furnished a child of the marriage in her custody unless by agreement, express or implied; that there must be either an express promise, or facts from which one can reasonably be inferred. Ramsey v. Ramsey, 121 Ind. 215; Cushman v. Hassler, 82 Iowa, 295. And. it has been considered that the support of the child, under such circumstances, by the mother, was but the voluntary performance of a natural duty, and that her remedy was to apply to the court for maintenance of the child when the divorce was granted. These, and other cases of a similar purport, are confidently relied on as decisive against the claimant.

In McGoon v. Irvin, 1 Pin. 532, where the husband had procured a legislative divorce from his wife, and had left the minor children of the marriage in a family of a third person to be supported, the mother afterwards obtained the custody of the children without his knowledge and consent, and refused, on demand made in behalf of the father, to give them up. She afterwards intermarried with I., and the children were supported and educated by him. In an action by L against the father to recover for their support, it was held that McG-. had a legal right to the custody of the children, but, as he had not attempted to assert it against I., the law would presume that McG-. had assented to their being in the control and custody of I.’s wife, their mother, and that I. could recover, though the act of the mother in obtaining the custody of the children before her second marriage might have been wrongful. And it was said by the court that “ when a parent permits a stranger to maintain, support, and instruct such children, in no way objecting to the act,, but rather assenting and advising therein, the law will presume that he knows his obligations, accepts the services, and assumes to pay.” It was also said that “ there was no duty or obligation on the plaintiff to notify the defendant to take the children away, or leave them to suffer until he could see [435]*435the defendant and make an express contract about their support and maintenance. Such a course would have merited the reprobation of every humane and upright man. .The defendant had the legal right to the possession, and could have enforced it at any time. He should have first moved in the matter, and, on failure to do so, the law would presume that possession elsewhere was with his approbation and consent.” In the leading case which holds the father liable, under circumstances like the present, the court approves the doctrine that, if a minor is forced out into the world by the cruelty or improper conduct of the father, necessaries may be supplied, and the value thereof may be recovered from the parent. There is evidently no satisfactory reason,” said the court, “for changing the rule of liability, when, through ill treatment or other breach of marital obligation, the husband renders it necessary for a court of justice to divorce the wife and commit to her the custody of her minor children. If, under such circumstances, upon the allowance of alimony with custody of children, the court omits to make an order for the children’s maintenance, the father’s natural obligation to support them is of none the less force. The duty of support is not evaded by the husband so conducting himself as to render it necessary to dissolve the bonds of matrimony and give to the mother the care and custody of the infant offspring. It is not the policy of the law to deprive children of their rights on account of the dissensions of their parents, to which they are not parties, or to enable the.father to convert his own misconduct into a shield against parental liability’-.” But, obviously, this reasoning can only apply where the husband is at fault and the decree is silent as to his liability. Pretzinger v. Pretzinger, 45 Ohio St. 45S, approved in Bishop, Mar., Div. & Sep. § 1223, and in Fulton v. Fulton, 52 Ohio St. 229.

It is to be borne in mind that the divorce in the instant [436]*436case was granted to tbe claimant against her husband, August Zilley, on tbe ground of bis cruel and inhuman treatment. It was bis marital wrongdoing which led to the separation of the parties and the award of the custody of the boy, Clayton, to the mother until he became of the age of ten years. The case as to the subsequent support of the boy, Clayton A.,

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Bluebook (online)
40 L.R.A. 579, 74 N.W. 126, 98 Wis. 428, 1898 Wisc. LEXIS 155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/zilley-v-dunwiddie-wis-1898.