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Mills v. Wyman

(1825)

Massachusetts Supreme Judicial Court - 3 Pick. [20 Mass.] 207, 3 Pick. 207, 20 Mass. 207

tl;dr:

A father found out that a stranger provided his son with shelter and comfort after his son fell ill. The son ultimately died, but the father promised to pay the stranger for the expenses he incurred caring for his son. But the father never sent payment.

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Case Summary

In the 1825 case Mills v. Wyman, the Massachusetts Supreme Judicial Court denied a payment claim related to a man's care for another's adult son.

Defendant Wyman’s son was traveling and fell ill. Plaintiff Mills provided Wyman’s son with shelter and comfort until he ultimately died. Wyman, after finding out about this, influenced by a feeling of gratitude, promised in writing to pay Mills for the expenses he had incurred. Then, Wyman decided to break his word and did not send any payment.

Mills sued the father, Wyman, for not paying him for the expenses he spent while caring for Wyman's son. The father claimed that no contract existed since there was no consideration from Mills. The trial court initially ruled in Mills' favor, and Wyman appealed.

On appeal, the court found that there was no valid contract between Mills and Wyman, citing the necessity of "consideration," or a benefit given by the promisor or a detriment to the promisee. In this case, the court found that Mills caring for Wyman's son didn't qualify as consideration since it happened before the promise was made and no payment was expected.

The court determined that Wyman's moral obligation to pay for his son's care was not legally binding, so it couldn't be considered valid consideration. Additionally, the court ruled that a father isn't responsible for an adult son's debts unless he expressly agrees to cover them.

ICRAIssue, Conclusion, Rule, Analysis for Mills v. Wyman

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Facts & HoldingMills v. Wyman case brief facts & holding

Facts:Defendant Wyman’s son was traveling and fell ill. Plaintiff Mills provided...

Holding:A moral obligation is not a sufficient consideration to support...

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Mills v. Wyman | Case Brief DeepDive
Majority opinion, author: Parker C. J.
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This case involves a dispute where the defendant promised to pay for expenses incurred by the plaintiff in caring for the defendant's sick son, but has refused to pay, arguing that there was no legal consideration for the promise. The law generally upholds the principle that promises made without compensation cannot be enforced, and any deviation from this rule would undermine the legal system. The article discusses the legal position on duties of imperfect obligation, which are as binding on the conscience as perfect obligations. The law only enforces promises where there is consideration, which can be something gained by the promisor or lost by the promisee. Moral obligation is only sufficient consideration for an express promise if a good or valuable consideration has existed at some point. Legal obligation is always sufficient consideration for an express or implied promise. The article also mentions that instruments under seal and certain mercantile contracts have their own rules regarding consideration.

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