North Carolina Baptist Hospitals, Inc. v. Harris
319 N.C. 347, 354 S.E.2d 471, 1987 N.C. LEXIS 2012 (1987)
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Rule of Law:
The common law 'doctrine of necessaries,' which traditionally held a husband liable for his wife's necessary expenses, is expanded to apply in a gender-neutral manner, making each spouse liable for the necessary expenses, including medical care, incurred by the other.
Facts:
- On January 20, 1982, Donnie Harris was admitted to North Carolina Baptist Hospital for necessary medical treatment.
- Donnie Harris was married to Vern Dell Harris at the time of his admission.
- At the hospital, Vern Dell Harris signed an authorization form for her husband's treatment, signing his name and adding 'by Vern Dell Harris.'
- Vern Dell Harris explicitly declined to sign a separate form that would have designated her as a guarantor of the bill.
- The hospital provided services totaling $3,303.61.
- Neither Donnie nor Vern Dell Harris paid the hospital bill.
Procedural Posture:
- North Carolina Baptist Hospital, Inc. (plaintiff) sued Donnie Harris and Vern Dell Harris (defendants) in the District Court, Yadkin County, to recover the cost of medical services.
- The trial court entered judgment against Donnie Harris but dismissed the plaintiff's action against Vern Dell Harris.
- The plaintiff hospital appealed the dismissal of its claim against Vern Dell Harris to the North Carolina Court of Appeals.
- The Court of Appeals affirmed the trial court's dismissal.
- The plaintiff hospital appealed to the Supreme Court of North Carolina.
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Issue:
Does the common law doctrine of necessaries apply to hold a wife liable for the necessary medical expenses incurred by her husband, even when she has not expressly agreed to pay for them?
Opinions:
Majority - Meyer, Justice
Yes, the common law doctrine of necessaries is expanded to apply in a gender-neutral fashion, making a wife liable for the necessary medical expenses provided to her husband. The court reasoned that the traditional, one-sided application of the doctrine was based on the archaic legal disability of married women, who historically could not manage their own finances. Citing legislative trends toward gender neutrality, such as the Equitable Distribution Act, and its own precedent in Mims v. Mims, the court found that these outdated notions no longer reflect modern society where marriage is viewed as an equal partnership. The court concluded that expanding the doctrine, rather than abolishing it, serves the beneficial functions of encouraging healthcare providers to render aid and recognizing that marriage involves shared duties and expenses. This duty arises from the marital relationship itself, so an attempt by a spouse to disavow it, such as by refusing to sign a guarantor form, is ineffective.
Analysis:
This decision modernizes a significant common law doctrine to align with contemporary understandings of marriage as an equal partnership and reflects broader legislative trends toward gender neutrality in domestic relations law. By making the duty of support for necessaries reciprocal, the court eliminated a gender-based distinction rooted in historical legal fictions about the roles of spouses. This ruling provides creditors, particularly healthcare providers, with an additional source of recovery for services rendered to a married person. It solidifies the principle that the marital unit entails shared financial responsibilities for essential needs, a duty imposed by law rather than by private contract.
