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Southern New Hampshire Medical Center v. Hayes

Supreme Court of New Hampshire
992 A.2d 596 (N.H. 2010)


Facts

Anthony and Karen Hayes (defendants) were married. Approximately 19 years into their marriage, Karen incurred extensive medical bills at Southern New Hampshire Medical Center (SNHMC) (plaintiff) for complications from alcoholism. During this time, Karen did not have health insurance, and the bills went unpaid. SNHMC brought suit against the Hayeses. The trial court granted summary judgment to SNHMC in terms of Karen’s liability and held a trial on the merits of Anthony’s liability. The Hayeses were legally married at the time Karen incurred the medical treatments, but Anthony presented evidence that he and Karen were separated at that time and had not lived as husband and wife for seven or eight years. Anthony thus raised elopement as an affirmative defense to his liability to SNHMC. The trial court granted SNHMC’s motion in limine to exclude any reference to elopement. The trial court accepted without deciding Anthony’s argument that a spouse was liable under the necessaries doctrine only if his or her debtor-spouse was unable to pay for necessaries. The trial court nonetheless found Anthony liable under the necessaries doctrine. Anthony appealed.

Rule of Law

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Issue

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Holding and Reasoning (Duggan, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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