Also known as: sui-juris · of one's own right · full legal capacity
Written by attorneys — see sources below.
A status of full legal capacity enjoyed by a natural person who is of full age and free from any recognized disability such as guardianship, minority, mental illness, or intoxication. A person in this status may incur binding contractual duties and exercise independent civil rights without the intervention of another. The status is determined by the absence of any disqualifying condition listed in the governing capacity rules.
Stephen Shaw, a twenty-five-year-old mechanic, negotiated and signed a three-year lease for diagnostic equipment with Summit Bank. He read the terms, asked questions about payment schedules, and made the first payment from his business account. When the bank later sought enforcement after a missed payment, Stephen could not avoid the obligation on capacity grounds because he possessed full legal capacity at the time of assent.
Sydney Santos, an adult baker, agreed with her employer to work more than sixty hours per week in exchange for higher wages. The state later enacted a statute capping hours for all adult workers. Santos argued that the statute improperly restricted her freedom to contract because she possessed full legal capacity and could decide her own working hours without state interference.
The New York legislature passed a labor law in 1897 that regulated bakeries and confectionery establishments. Section 110 of article 8 of that law stated that no employee shall be required or permitted to work more than sixty hours in any one week or more than ten hours in any one day. This applied unless for the purpose of making a shorter work day on the last day of the week. The plaintiff in error violated the one hundred and tenth section of article 8, chapter 415, of the Laws of 1897, known as the labor law of the State of New York, in that he wrongfully and unlawfully required and permitted an employe working for him to work more than sixty hours in one week. The charge arose from a voluntary contract rather than any use of physical force. The judgments of the County Court of Oneida County, the Supreme Court, and the Court of Appeals of New York upheld the conviction under the statute, although several judges dissented. The record indicated that the state courts had viewed the law as a measure relating to public health. The case came before the Supreme Court of the United States after argument on February 23 and 24, 1905. The Court rendered its decision on April 17, 1905.
View caseSamantha Stone obtained a divorce from bed and board that left the marital bond intact. She then sued her former husband in another state for alimony. The court treated her as possessing full legal capacity to maintain the separate action because the limited divorce did not suspend her independent civil rights.
Hiram Barber and Huldah Adeline Barber were married in the State of New York in 1840. Huldah, through her next friend George Cronkhite, a citizen of New York, applied for a divorce a mensa et thoro in the court of chancery for the fourth district of New York. The defendant appeared and resisted the application. The cause was heard on the pleadings and proofs, resulting in a decree that Hiram had been guilty of cruel and inhuman treatment and had abandoned and refused to provide for his wife. The New York court decreed that the parties be separated from bed and board forever, referred the cause to a master to ascertain alimony, overruled the defendant's exceptions to the master's report, and entered a final decree awarding Huldah $360 per year in quarterly installments for her support, with $960 due retroactively from July 1, 1844, plus costs, and future quarterly payments during her life, vested in her as separate estate. A transcript of the authenticated New York record formed the basis for the subsequent federal suit. Hiram left New York shortly after the decree without paying any alimony and without leaving assets there to satisfy it, establishing residence in Wisconsin. In April 1852 he obtained a divorce a vinculo from the Circuit Court of Dodge County, Wisconsin, without disclosing the New York proceedings. Huldah remained in New York as her domicil. Huldah, by her next friend, filed suit on the equity side of the United States District Court for the District of Wisconsin against Hiram, a Wisconsin citizen, alleging $4,242.15 due on the New York decree with interest. Hiram demurred on grounds including that the case was not within chancery jurisdiction and that relief could only be had in New York; the demurrer was overruled. He answered, admitting the New York decree and his nonpayment but asserting the Wisconsin divorce rendered Huldah a feme sole who could not sue by next friend and that any remedy lay at law. After a general replication, hearing on pleadings and proofs, the district court decreed $5,936.80 due for principal and interest to the date of the bill, ordering payment with costs.
View caseSofia Stern, an adult laundry owner, contracted with employees for shifts longer than the state maximum. After the state enforced the limit against her, she challenged the statute as an improper restriction on the liberty of persons who possess full legal capacity to arrange their own labor contracts.
On February 19, 1903, the legislature of the State of Oregon passed an act whose first section provided that no female shall be employed in any mechanical establishment, or factory, or laundry in this State more than ten hours during any one day. Subsequently, on September 18, 1905, an information was filed in the Circuit Court of the State for the county of Multnomah charging that Curt Muller, the owner of a laundry known as the Grand Laundry in the city of Portland, had unlawfully permitted his overseer Joe Haselbock to require a female employee, Mrs. E. Gotcher, to work more than ten hours on September 4, 1905. A trial in the circuit court resulted in a verdict against the defendant, who was sentenced to pay a fine of ten dollars. The Supreme Court of the State affirmed the conviction in State v. Muller, 48 Oregon 252, after which the case was brought to the United States Supreme Court on a writ of error. It is the law of Oregon that women, whether married or single, have equal contractual and personal rights with men, as recognized in decisions such as First National Bank v. Leonard. In the brief filed before the Court on behalf of the defendant in error, there was presented a copious collection of legislation from states such as Massachusetts, Rhode Island, and Louisiana along with reports from committees and factory inspectors concerning the effects of long hours of labor on women.
View caseA natural person lacks this status when under guardianship, an infant, mentally ill or defective, or intoxicated. Each condition removes the presumption of full capacity to incur contractual duties.
Supporting sources
No. The status establishes presumptive capacity, but a contract may still be voidable for other reasons such as fraud, duress, or unconscionability even when both parties possess full legal capacity.
A minor is not sui juris and therefore lacks full capacity. The minor may incur only voidable duties, allowing disaffirmance even when the contract appears otherwise valid.
Supporting sources
…seriously limits the right to labor or the right of contract in regard to their means of livelihood between persons who are sui juris (both employer and employe), it becomes of great importance to determine which shall prevail — the right of the individual to labor for such time as he may choose, or the right of the…