Mills v. Wyman - Brief PDF

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Restitution Mills v. Wyman COURT AND DATE: Supreme Judicial Court of Massachusetts (1825) PROCEDURAL HISTORY: ISSUE: Whether a promise based on a moral obligation but made without legal consideration constitutes an enforceable contract.

TRIGGER FACTS: On February 5, 1821, Mills (plaintiff), a Hartford, Connecticut resident, came upon Levi Wyman, the son of Wyman (defendant). Levi was twenty-five years old and had just returned from a voyage at sea. He was extremely ill, and was taken in and cared for by Mills, a stranger, for fifteen days. Levi then died. His father, Wyman, lived in Massachusetts and wrote to Mills upon hearing of Levi’s death. Wyman promised to pay Mills for the expenses he incurred while taking care of Levi. However, Wyman later refused to pay and Mills brought suit to enforce Wyman’s promise. The court of common pleas held for Wyman and ruled the promise unenforceable. Mills appealed.

PLAINTIFF’S MAIN ARGUMENTS: DEFENDANT’S MAIN ARGUMENTS: RULE (the law): A promise based on a moral obligation but made without legal consideration does not constitute an enforceable contract unless it is tied to a preexisting legal obligation.

HOLDING + REASONING (Brennan, J.): No. The promise made by Wyman to pay for Mills’ expenses is without legal consideration and thus unenforceable. A promise based on a moral obligation but made without legal consideration does not constitute an enforceable contract unless it is tied to a preexisting legal obligation. A promise may be tied to a preexisting legal obligation if the original legal obligation was based on consideration. For example, when one promises to assume the debt of another who cannot pay, this promise is enforceable because of the consideration originally provided by the initial debtor to the lender. Additionally, a parent’s promise to pay the debts of his minor children is enforceable based on the preexisting legal duty of parents to provide for their children’s expenses. However, this obligation dissolves once the child reaches adulthood. Levi Wyman fully reached adulthood and had long been out of his father’s care. Thus, his father is no longer obligated to pay his debts based on a preexisting parent-child relationship. Additionally, no original promise supported by valid consideration existed between Levi and Mills such that his father’s promise to assume Levi’s debts could be tied to this preexisting legal obligation. Thus, Wyman’s promise to pay the expenses incurred by Mills while caring for his son, while perhaps a moral obligation was not supported by legal consideration and does not constitute a valid and enforceable contract. The decision of the court of common pleas is affirmed.

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