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Accounts Management, Inc. v. Litchfield

576 N.W.2d 233 (1998)

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Accounts Management, Inc. v. Litchfield

South Dakota Supreme Court

576 N.W.2d 233 (1998)

Facts

Fredrick Klusman and Claudia Caswell (defendant) applied for a marriage license on December 20, 1984, and were married four days later by an ordained Presbyterian minister in a ceremony in front of their friends and relatives. The marriage license was never recorded. On October 14, 1986, Klusman had a severe heart attack and was admitted for seven days to the intensive-care unit of St. Joseph Hospital. Caswell signed Klusman’s admissions forms as “Claudia Klusman, wife.” Klusman suffered severe and irreversible brain damage because of the heart attack, and Caswell assumed guardianship of his person and affairs until his death in 1989. St. Joseph billed Klusman $14,170 for his care, and Caswell made consistent monthly payments for eight years before stopping in August 1994. Accounts Management Inc. (AMI) (plaintiff) took over the debt and sued Caswell for the remaining balance. The circuit court granted AMI’s motion for summary judgment, and Caswell appealed, alleging she had no responsibility for Klusman’s medical bill because their marriage was invalid.

Rule of Law

Issue

Holding and Reasoning (Konenkamp, J.)

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