Jackson v. Jackson
23 L. Ed. 258, 91 U.S. 122, 1875 U.S. LEXIS 1341 (1875)
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Rule of Law:
When a husband, who is free from debt, permits his wife to invest money that legally belongs to him under the common law (such as her pre-marital assets and subsequent earnings) in real property titled in her name, the transaction is presumed to be a valid voluntary settlement or advancement for her benefit, not a resulting trust in his favor.
Facts:
- A woman received money from her father prior to her marriage.
- After marrying, she used this money to purchase a parcel of land, taking the deed in her own name.
- She subsequently constructed buildings on the land, funding the construction partly with the money from her father and partly with her own earnings acquired during the marriage.
- The contract for the construction of the houses was made by the wife alone.
- The insurance policy on the buildings was executed in the wife's name, and she paid the property taxes.
- Under the governing common law of the District of Columbia at the time, a wife's pre-marital personal property and any subsequent earnings belonged exclusively to her husband.
- The husband was free from debt at the time the land was purchased and the improvements were made.
- For fifteen years, the husband acquiesced in his wife holding the property in her name and making improvements upon it.
Procedural Posture:
- This case arose from a property dispute following a divorce decree.
- The Supreme Court of the District of Columbia, acting as the court of first instance, granted the divorce for cruel treatment by the husband.
- In its decree, the trial court awarded a portion of the real property held in the wife's name to the husband and ordered her to execute a conveyance to him.
- The wife appealed the portion of the decree concerning the division of property to the Supreme Court of the United States.
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Issue:
Does a husband retain an ownership interest in real property purchased and improved in his wife's name using money that, under the common law, legally belonged to him (including her pre-marital funds and subsequent earnings), when he was free from debt at the time of the transactions?
Opinions:
Majority - Justice Field
No. A husband does not retain an ownership interest because allowing his wife to use his funds to purchase property in her name constitutes a valid voluntary settlement or advancement for her benefit. The law presumes that when a husband provides funds for a purchase in his wife's name, he intends it as a gift or provision for her, not as a resulting trust for himself. This presumption arises from the husband's legal and moral obligation to provide for his wife, thereby rebutting the usual presumption that the party who furnishes the purchase money intends to enjoy the benefit of the property. Citing Sexton v. Wheaton, the court affirmed that a voluntary settlement on a wife by a husband who is not in debt is valid against the husband's subsequent claims, provided it was not made with fraudulent intent toward existing creditors. The husband's fifteen years of acquiescence in the wife's ownership and improvement of the property serves as sufficient evidence of his original authorization of the settlement.
Dissenting - Justice Davis
Yes. While the legal propositions advanced by the majority are correct, the evidence presented in this specific case does not warrant their application. The facts of the case justified the lower court's conclusion that the property should be divided between the husband and wife.
Analysis:
This decision reinforces the legal principle that the presumption of a resulting trust is rebutted by the existence of a close family relationship, such as that between a husband and wife. It establishes that a husband's transfer of property to his wife, even using funds that were legally his under the doctrine of coverture, is treated as an irrevocable gift or 'advancement' absent evidence of fraud against existing creditors. The ruling provided a measure of protection for a married woman's property rights against later claims by her husband, particularly in divorce proceedings, by solidifying the character of such transactions as completed settlements.
