Summary of Mills v. Wyman
Citation: 20 Mass. 207 (1825)
Relevant Facts: Following a long voyage at sea, Levi Wyman fell ill and found himself in Hartford, Connecticut. He did not know anyone in the community. Plaintiff Daniel Mills took Levi in and provided him with room, board, and care. After a two-week illness, Levi passed away. Thereafter, Levi’s father, Seth Wyman, wrote to Mills and agreed to pay for the expenses he had incurred on behalf of Wyman’s son. At the time of his illness and the provision of services, Levi Wyman was twenty-five years old and thus not a minor. Defendant Seth Wyman did not have a pre-existing relationship with Mills nor did he agree to pay any expenses on behalf of his son until after the debts had been incurred. Seth Wyman reneged on his promise to pay his son’s expenses, and Plaintiff brought suit in assumpsit. At trial, the Court directed a nonsuit for failure of legal consideration, and this appeal followed.
Issue: Is a moral obligation alone, flowing from a promise to pay, sufficient consideration to create a valid contract to repay debts that have already been incurred by an adult child of the promisor?
Holding: No, a promise- and moral obligation- alone is insufficient consideration to create a legal obligation to perform a moral duty.
Reasoning : Chief Judge Parker delivered the opinion of the Court. The majority begin by explaining the universally recognized principle that putative contracts, absent consideration, are not actually enforceable agreements, even where refused enforcement leads to a regrettable result. While admitting that moral obligations, and accompanying promises, are at times given legal effect by Courts, Judge Parker explained that such a holding was hardly compelled. Rather, a promise to pay a debt that has already been incurred is insufficient to form a legal obligation. The majority distinguished this case from others in which mere promises were given legal effect, such as where collecting a debt is barred by the statute of limitations but revived by subsequent promise. In those cases, however, the enforceable promise merely served to waive a legal limitation on an otherwise valid contract. In this case, the plaintiff attempted to enforce a binding agreement based solely on the promise of payment. While the defendant violated a moral duty to keep his word, and make good on his promises, the general rules of contract construction lead to the unavoidable conclusion that no contract was created; accordingly, no legal obligation to make payment was incurred. The majority distinguished this case from that of a parent paying expenses incurred by a child, as the “child" in this case was well past the age of majority. Finally, the Court determined that a state statute requiring relatives to pay for the expenses that would otherwise be incurred by the community did not apply on the facts before the Court. While additional factual findings regarding the expenses of the deceased and the means of the defendant may have made the statute applicable, the Court could not apply it here absent additional findings. Furthermore, the statute in questions was limited to the specific instances cited and the Court had inadequate information to conclude that the circumstances here compelled payment. In the absence of a valid contract or a statutory duty to make payment, judgment was properly rendered for the defendant.
Dissent: None, unanimous decision.
Conclusion: Moral obligations alone are insufficient to provide valid consideration for a binding contract. The Court will not enforce a moral obligation; rather, the Court will only enforce a valid contract following a determination that the contract in question is legally sufficient.