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Kirchberg v. Feenstra

United States Supreme Court
450 U.S. 455 (1981)


Facts

Joan Feenstra (defendant) filed a criminal complaint against her husband, Harold Feenstra, for allegedly molesting their minor daughter. While incarcerated on the charge, Harold retained attorney Karl Kirchberg (plaintiff) for representation. In exchange for Kirchberg’s legal services, Harold signed a $3,000 promissory note in favor of Kirchberg. Harold then executed a mortgage in favor of Kirchberg, using the home jointly owned by Harold and Joan as security on the note. A Louisiana statute, known as the head-and-master rule, allowed Karl, as the husband, to manage jointly held real property without Joan’s knowledge or consent. Joan was unaware of the mortgage, which was signed solely by Harold. Joan later dropped the criminal charge against Harold, but the Feenstras did not reunite. Harold moved out of the home, and the Feenstras separated. Harold failed to pay the $3,000 owed to Kirchberg, and after Joan learned of the promissory note’s existence, she also refused to pay. Consequently, Kirchberg obtained an order directing the local sheriff to seize and sell the Feenstras’ home. Kirchberg then filed suit in federal district court, seeking a declaratory judgment against Joan that he was not required to disclose to her the existence of the mortgage that he held on her home. Joan counterclaimed, asserting that Kirchberg was required to make that disclosure and that the Louisiana statute establishing the head-and-master rule, was unconstitutional. The State of Louisiana and its governor were joined as third-party defendants on the constitutionality claim. The district court granted summary judgment in favor of the defendants. Joan appealed. The court of appeals reversed and held that the head-and-master rule violated the Equal Protection Clause. The United States Supreme Court granted certiorari to review.

Rule of Law

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Issue

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Holding and Reasoning (Marshall, J.)

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