Stier v. Price
37 So. 2d 847, 1948 La. LEXIS 976, 214 La. 394 (1948)
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Rule of Law:
The discovery, after marriage, that a spouse had an undisclosed, pre-existing mental illness is not a 'mistake respecting the person' or a lack of free consent sufficient to serve as grounds for annulment under the Louisiana Civil Code.
Facts:
- On November 12, 1935, Madeleine Stier married Charles E. Price.
- At the time of the marriage, Stier was unaware of any impediment to the union and claims she would not have consented had she known of Price's condition.
- Unbeknownst to Stier, Price had been suffering from dementia praecox since October 1929.
- Prior to the marriage, in October 1929, Price was admitted to the East Louisiana State Hospital and diagnosed with dementia praecox.
- After the marriage, Price was admitted to the same hospital on three separate occasions for the same condition.
- Stier lived with Price as his wife for almost 12 years before seeking an annulment.
- Price has never been formally and legally interdicted (declared mentally incompetent by a court).
Procedural Posture:
- Madeleine Stier filed a suit against her husband, Charles E. Price, in a Louisiana trial court, seeking to annul their marriage.
- A curator ad hoc, appointed to represent Price, filed an exception of no cause or right of action, which is a motion to dismiss the case for failing to state a valid legal claim.
- The trial court sustained the exception and dismissed Stier's lawsuit.
- Stier, as the appellant, appealed the trial court's judgment to the Supreme Court of Louisiana.
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Issue:
Does a party's discovery after marriage that their spouse was suffering from an undisclosed mental illness at the time of the wedding constitute a lack of 'free consent' or a 'mistake respecting the person' that justifies an annulment under the Louisiana Civil Code?
Opinions:
Majority - Hawthorne, Justice.
No, the discovery that a spouse was insane at the time of marriage does not constitute a lack of free consent or a 'mistake respecting the person' that would justify an annulment. The grounds for annulment are strictly enumerated in the Civil Code, and a mistake as to a spouse's qualities, such as their mental health, does not qualify. The court reasoned that 'free consent' under Article 91 is only absent in cases of kidnapping, violence, or a mistake of physical identity. Citing Delpit v. Young, the court affirmed that 'mistake respecting the person' is limited to errors of identity, not errors regarding a person's character, health, social standing, or habits. To allow annulment for the discovery of a pre-existing condition like insanity would improperly broaden the narrow grounds established by the legislature. Furthermore, the court held that any claim regarding the husband's own lack of consent due to his insanity could only be raised by him or his legal representative, not by Stier.
Analysis:
This decision strictly construes the grounds for annulment in Louisiana, cementing the principle that a 'mistake respecting the person' refers only to a mistake of physical identity, not a mistake about a person's qualities, health, or character. The ruling significantly narrows the path to annulment based on fraud or misrepresentation about pre-marital conditions, prioritizing the stability of the marital contract over a party's subjective, post-nuptial discoveries. It establishes a clear precedent that parties assume the risk of discovering 'redhibitory vices,' such as undisclosed mental or physical health issues, in their partners after marriage, and such discoveries are not grounds for annulment.
