Quick Summary
Steven Kiefer (plaintiff) bought a car from Fred Howe Motors, Inc. (defendant) but encountered problems and sued for reimbursement. The issue before the Wisconsin Supreme Court was whether an emancipated minor over eighteen should be bound by their contracts and if Kiefer had effectively disaffirmed his contract.
The court affirmed the trial court’s judgment in favor of Kiefer, upholding the doctrine that minors’ contracts are voidable and finding no evidence of misrepresentation on Kiefer’s part.
Facts of the Case
Steven Kiefer (plaintiff), a working father and husband not yet twenty-one, bought a car from Fred Howe Motors, Inc. (defendant). In Wisconsin at the time, the age of majority was twenty-one. Kiefer encountered problems with the vehicle and attempted to return it to Howe Motors.
Subsequently, Kiefer initiated legal action against Howe Motors, seeking reimbursement for the car’s sale price. The trial court ruled in favor of Kiefer, prompting Howe Motors to appeal.
Procedural History
- Kiefer purchased a vehicle from Howe Motors.
- Kiefer experienced issues with the car and attempted to return it.
- Kiefer filed a lawsuit against Howe Motors for the sale price of the car.
- The trial court entered judgment for Kiefer.
- Howe Motors appealed the decision to the Wisconsin Supreme Court.
I.R.A.C. Format
Issue
Whether an emancipated minor over the age of eighteen should be legally responsible for his contracts and whether the contract was effectively disaffirmed.
Rule of Law
The general rule is that a minor’s contract, other than for necessaries, is voidable at their discretion, regardless of their status as emancipated or unemancipated.
Reasoning and Analysis
The Supreme Court of Wisconsin was asked to reconsider the longstanding doctrine that minors can disaffirm contracts. The court acknowledged modern societal changes that challenge the traditional view of a minor’s maturity and contractual capacity.
However, the court decided not to change this doctrine unilaterally, suggesting legislative action as a more appropriate avenue for such reform. The court also found that Kiefer effectively disaffirmed his contract by expressing his intent to do so and that he could not be held liable for misrepresentation as there was no evidence of intent to defraud or justifiable reliance by Howe Motors on his age.
Conclusion
The judgment in favor of Kiefer was affirmed by the Wisconsin Supreme Court.
Dissenting Opinions
Chief Justice HALLOWS dissented, arguing that emancipated minors should be responsible for their contracts and that an automobile might be considered a necessity for a working parent under twenty-one, which would make the contract non-disaffirmable.
Key Takeaways
- A minor’s contract is voidable at their discretion unless it is for necessaries or falls within certain exceptions.
- The Wisconsin Supreme Court suggested legislative action rather than judicial action to change the doctrine regarding minors’ contracts.
- An emancipated minor’s marital status does not confer upon them the legal capacity to enter into binding contracts if they are under the age of majority.
- The court did not find any evidence of intent to defraud or justifiable reliance, thus ruling out misrepresentation by Kiefer.
Relevant FAQs of this case
What determines if a contract with a minor is enforceable or voidable?
A contract involving a minor is typically voidable at the minor’s discretion unless it is for necessaries like food, clothing, or shelter. Courts will review the nature of the contract and the age of the minor to decide on enforceability. A minor can disaffirm a contract up until reaching the age of majority or a reasonable time thereafter, but they cannot disaffirm contracts for necessaries.
- For example: A 17-year-old purchasing a luxury item could later opt to void the contract, as it is not considered a necessity.
How does emancipation affect a minor's capacity to enter into contracts?
Emancipation may grant a minor certain adult responsibilities and rights, but it generally does not alter their legal capacity to enter into contracts. Contracts made by an emancipated minor remain voidable just as they are for non-emancipated minors, except in cases involving necessaries where the law may recognize an exception.
- For example: An emancipated 16-year-old signing a lease for an apartment could be an exception where the contract would be binding as housing is a necessity.
Can a seller rely on a buyer’s appearance of age to enforce a contract?
No, a seller cannot solely rely on the appearance of age unless there was an intentional misrepresentation of age by the buyer. Courts generally require sellers to take reasonable steps to ascertain the buyer’s age. If due diligence is not performed, and the buyer is a minor, the contract is typically voidable at the discretion of the minor.
- For example: A car dealer failing to check identification that would reveal the true age of a minor buyer cannot hold the minor to the car purchase agreement.
References
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