In Matter of Estate of Steffes
95 Wis. 2d 490, 290 N.W.2d 697, 1980 Wisc. LEXIS 2537 (1980)
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Rule of Law:
A party may recover compensation under a contract implied in fact for the reasonable value of lawful services rendered, even if the party was engaged in an illicit relationship with the recipient, so long as the agreement for services is independent of and not consideration for the illicit relationship. Denying recovery for lawful services independent of the relationship would result in unjust enrichment of the recipient's estate.
Facts:
- In 1969, Mary Lou Brooks met Virgil Steffes and soon after moved into his farm home, where she resided until his death in 1976.
- Throughout their cohabitation, both Brooks and Steffes remained legally married to other individuals.
- Brooks and Steffes engaged in a sexual relationship that continued until approximately one year before his death.
- During the last two years of Steffes's life, Brooks performed extensive services, including all housekeeping, significant farm labor (such as running a combine and pouring concrete), bookkeeping, and comprehensive nursing care after he was diagnosed with a brain tumor.
- Steffes expressed to his brother-in-law and friends his intent to provide for Brooks and leave her his house and farm upon his death, but he died without a will.
- In the final two years, Steffes provided Brooks with food, lodging, approximately $7,200 from the sale of animals he had given her, and $3,200 toward the purchase of a car.
Procedural Posture:
- Virgil Steffes died without a will on July 17, 1976.
- Mary Lou Brooks filed a claim for $29,200 against the Estate of Virgil Steffes in the trial court, seeking compensation for personal services.
- The estate, through its personal representative, refused to pay the claim.
- The trial court entered a judgment in favor of Brooks, awarding her $14,600 for the reasonable value of her services.
- The personal representative for the Estate of Steffes appealed the trial court's judgment to the Supreme Court of Wisconsin.
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Issue:
Does a claimant's adulterous relationship with a decedent bar recovery under an implied contract for the reasonable value of household, farm, and nursing services rendered to the decedent?
Opinions:
Majority - Shirley S. Abrahamson, J.
No, a claimant's adulterous relationship with a decedent does not bar recovery under an implied contract for the reasonable value of lawful services. A bargain for services is not rendered illegal merely because an illicit relationship exists between the parties, so long as the bargain is independent of the illicit relationship and the sexual acts do not form part of the consideration. The court found sufficient evidence to imply a contract for compensation based on the extensive, commercial nature of the services rendered, Brooks's expectation of compensation, and Steffes's stated intent to provide for her. The trial court correctly determined that the illicit relationship was incidental to the agreement for services, and denying recovery would unjustly enrich the decedent's estate.
Dissenting - Coffey, J.
Yes, the claimant's adulterous relationship should bar her recovery on public policy grounds. Allowing compensation validates a relationship that contravenes the public policy of Wisconsin and undermines the institution of marriage as protected by the state's Family Code. The services rendered were not independent of the meretricious relationship; rather, the entire living arrangement was founded upon it. The court should leave the parties as it finds them and not provide a judicial remedy that condones illegal and immoral conduct, as such a significant policy decision should be left to the legislature.
Analysis:
This decision establishes that courts in this jurisdiction will sever a lawful contract for services from a concurrent illicit relationship when determining enforceability. It moves away from a strict public policy bar, focusing instead on whether the illicit conduct was the actual consideration for the agreement. The case is significant for allowing recovery in quasi-contract to prevent unjust enrichment even in the context of a "meretricious relationship," provided the services themselves are lawful. This sets a precedent for analyzing the severability of legal and illegal aspects of informal domestic arrangements, impacting future claims by unmarried cohabitants.
