Cheshire Medical Center v. Holbrook
New Hampshire Supreme Court
663 A.2d 1344 (N.H. 1995)
- Written by Jamie Milne, JD
Facts
In 1993, New Hampshire resident Rachel Holbrook (defendant) received medical care at Cheshire Medical Center (Cheshire) (plaintiff). Rachel was subsequently incarcerated and was unable to pay the $7080.40 due for her treatment. Unhappy with Rachel’s proposed repayment plan, which would have required Rachel to pay only $10 per month while imprisoned, Cheshire sued Rachel and her husband, Robert Holbrook (defendant). Cheshire sought to hold Robert financially liable for the debt under the common-law doctrine of necessaries. Robert raised a question as to whether the doctrine remained valid law in New Hampshire, arguing that the doctrine violated equal protection by rendering husbands liable for wives’ necessaries but not rendering wives liable for husbands’ necessaries. The trial court certified a question to the New Hampshire Supreme Court, seeking guidance regarding the ongoing viability of the necessaries doctrine.
Rule of Law
Issue
Holding and Reasoning (Johnson, J.)
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