Southern New Hampshire Medical Center v. Hayes

Karen Hayes incurred extensive unpaid medical bills for alcoholism-related complications at Southern New Hampshire Medical Center (plaintiff), and the hospital sued both Karen and her husband Anthony (defendants) under the necessaries doctrine; Anthony argued he and Karen had been separated and living apart as husband and wife for seven or eight years despite remaining legally married, raising this estrangement (elopement) as an affirmative defense. The trial court excluded evidence of the estrangement, accepted without formally deciding that liability required the debtor-spouse's actual inability to pay, but still found Anthony liable; he appealed.