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Coolidge v. Pua'aiki
Hawaii Supreme Court
3 Haw. Rep. 810 (1877)
Facts
H. J. Coolidge (plaintiff) owned and managed a plantation in Hawai’i. Coolidge’s wife, M. A. Coolidge, managed the plantation in his temporary absence. When Mr. Coolidge returned, he resumed managing the plantation and adopted all of his wife’s managerial actions, including labor contracts that she signed with Pua’aiki and Kea (defendants). Mr. Coolidge sued to enforce those contracts. At trial, Pua’aiki did not accuse either Mr. or Mrs. Coolidge of breaching the contract. However, Pua’akai contended that the contract was void for lack of mutuality. Pua’aiki pointed out that Mr. Coolidge had not delegated his managerial duties to Mrs. Coolidge in writing. Therefore, Pua’aiki argued, Mrs. Coolidge had no authority to subject her husband to the Hawai’i statute that made employers civilly and criminally liable for mistreating their employees. After the trial court entered judgment for Mr. Coolidge, Pua’aiki appealed to the Hawai’i Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Harris, C.J.)
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