North Carolina Baptist Hospitals, Inc. v. Harris

354 S.E.2d 471 (1987)

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North Carolina Baptist Hospitals, Inc. v. Harris

North Carolina Supreme Court
354 S.E.2d 471 (1987)

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Facts

Donnie Harris (defendant) was admitted to a hospital owned by North Carolina Baptist Hospitals, Inc. (plaintiff) for necessary medical treatment. Before Donnie could be treated, the hospital provided Donnie's wife, Vern Dell Harris (defendant), a form to sign, which authorized Donnie's treatment. Vern Dell signed Donnie's name, and under it signed, “by Vern Dell Harris.” However, Vern Dell did not sign as the guarantor. The hospital charged $3,303.61 for the services provided to Donnie. Neither Donnie nor Vern Dell paid the bill. The hospital sued Donnie and Vern Dell, arguing that Vern Dell was also liable for payment under the necessaries doctrine, which is a common-law doctrine providing that one spouse is liable for the necessary expenses of the other spouse. The trial court dismissed the hospital's action against Vern Dell, and the court of appeals affirmed the trial court's ruling. The hospital appealed.

Rule of Law

Issue

Holding and Reasoning (Meyer, J.)

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