Key Takeaways

  • Contracts with minors are generally voidable at the minor’s discretion due to presumed lack of legal capacity.
  • Some contracts, such as those for necessaries or employment (especially in entertainment), are enforceable.
  • Misrepresentation by minors doesn’t necessarily make a contract binding, but it may impact restitution.
  • Real-world case examples clarify how courts approach minor contract disputes.
  • Upon reaching the age of majority, minors must promptly disaffirm contracts or risk ratification.
  • Seeking legal help can clarify options when dealing with minor-related contract disputes.

Contract law cases involving minors can be difficult. Minors are often considered anyone 21 years of age or younger, though some states put the age of minors at 18 years old. The terminology of infant and minor can be used to mean the same thing in many states.

Rules to Follow When Creating a Contract With a Minor?

When you enter into a contract with a minor, you are doing so at your own peril. Legal contracts with minors can be easily voided if they see fit, which can leave the contracting party exposed. Many jurisdictions will rule in favor of laws protecting minors from contracted obligations as it is felt that they are not yet competent enough to understand a contract and the obligations they might be agreeing to.

If a minor reaches the legal age of maturity and they are still under a contract when it occurs, then they will have a reasonable time limit during which they can choose to void the contract.

Legal Capacity and the Doctrine of Infancy

In contract law, the doctrine of infancy refers to the principle that minors (typically under 18) lack the full legal capacity to enter binding agreements. This presumption aims to protect minors from exploitation due to their perceived immaturity and inexperience.

However, legal capacity doesn't entirely prevent minors from entering contracts. They may enter contracts that are beneficial and fair, but these contracts are typically voidable at the minor’s option—not automatically void. This distinction is critical in litigation, especially in minor contract law cases examples, where courts assess the fairness and context of the agreement.

What Does it Mean if a Contract is Voidable?

A contract can be considered voidable when it has the ability to be voided by either of the parties entering into it. Minors entering into a contract before the age of maturity will provide this option for either party. If someone above the age of maturity enters into a contract with a minor, the minor will have the option to void the contract but the adult won't.

There are some contracts that minors will not have the ability to void. These include:

  • Taxes
  • Penalties
  • Bank regulations
  • Necessities
  • Military contract

The biggest area concerning enforceable contracts with minors deals with contracts of necessaries. If a minor enters into a contract for the following items, the contract cannot be voided due to a minor not having the capacity.

  • Comfort
  • Education
  • Health

When a contract with a minor is voided, there are certain laws that are required to be followed. If a minor has obtained something from the contract and it is voided, the property will need to be returned. If the property is not returned, the contract cannot be voided.

Minor Contract Law Cases Examples

Real-world legal cases help illustrate how courts interpret and enforce contracts involving minors:

  • Nash v. Inman (1908): A landmark English case where a minor bought expensive clothing from a tailor. The court ruled the contract unenforceable since the goods were not "necessaries"—the minor already had sufficient clothing.
  • Doyle v. Giuliucci (1965): In this California case, a minor signed a baseball contract. The court upheld it, as entertainment and sports contracts—when court-approved—can bind minors.
  • Halbman v. Lemke (1980): A 17-year-old bought a used car, then disaffirmed the contract. The court allowed the disaffirmance and refused to require restitution because the vehicle had deteriorated, reinforcing the minor’s right to rescind.
  • Ryder v. Finchum (1943): A minor misrepresented their age to lease a vehicle. The court ruled that misrepresentation did not validate the contract, maintaining the minor’s right to void the agreement.

These minor contract law cases examples demonstrate how outcomes depend on factors such as necessity, misrepresentation, and the nature of the goods or services.

Exceptions for Creating Contracts With Minors

Considering a contract with a minor can easily be invalidated, it seems that no one would want to enter into a contract with a minor. There are exceptions so that minors can enter into contracts as well as ones to prevent minors from abusing the ability to void the contract.

Some types of contracts that can be an exception to the rules include:

  • Entertainment and sports contracts: These cannot be voided at will.
  • Necessaries: Goods or services that are necessary for the health and safety of the minor cannot be voided. These contracts can involve goods and services for such things as clothing, food, and shelter. Sometimes vehicles can also be considered necessary.
  • Disaffirming the whole contract: If a minor decides to void a contract, they must void the whole contract.
  • Ratification: A contract can only be voided when the minor is under the age of maturity. If they do not choose to void it before they reach the age of maturity, they lose the right to void the contract.
  • Bank accounts: Courts will often require minors to comply with any banking agreements that they made allowing minors to be subject to fees and penalties that non-minors will be subject to.
  • Employment contracts: Since many people under 18 will have some form of employment, the employer will have the right to enforce employment contracts. In the entertainment industry, sometimes courts will have to approve the contract to prevent it being voided later. There is also the possibility for parents to enter into employment contracts binding the minor.
  • Other contracts: Certain states will have their own requirements for contracts in regards to minors.

Impact of Misrepresentation by Minors

Misrepresentation by a minor—such as falsely claiming to be of legal age—can complicate the enforcement of a contract. While some courts may deny a minor the right to void a contract in cases of fraud, others maintain the doctrine of protection, emphasizing that the minor’s capacity cannot be waived by deception.

In general:

  • The contract may still be voidable even if the minor misrepresented their age.
  • Restitution may be required if the misrepresentation led to unfair enrichment.
  • Some states allow estoppel to prevent minors from using their age as a defense in fraud-based scenarios.

Understanding the implications of misrepresentation is key in evaluating minor contract law cases examples, especially in high-value or commercial transactions.

Voiding a Contract

There are two ways in which a contract can be voided. This can include filing a lawsuit that requests the court voids the contracts and the other is through a defense when they are being sued for violation of a contract. A minor must void the whole contract if they choose to void at all; they cannot void specific sections. The minor may also be required to pay some form of restitution for products or services that they have already received.

Timing and Method of Disaffirmance

Disaffirmance must be made within a reasonable time after reaching the age of majority. Delayed action may result in implied ratification, where continued use of the contract’s benefits or failure to act leads the court to assume acceptance.

Key points:

  • A minor can disaffirm either orally, in writing, or through actions that clearly reject the contract.
  • Full disaffirmance is required—minors cannot selectively void parts of a contract.
  • If the minor retains the goods or continues using services post-majority, it may indicate ratification.

Common Types of Contracts Enforced Against Minors

Although most contracts with minors are voidable, courts do enforce certain agreements. These typically serve a minor’s essential needs or broader public interests:

  1. Contracts for Necessaries: Include food, shelter, medical care, education, and sometimes transportation.
  2. Employment Contracts: Especially in entertainment or sports, courts may require approval to ensure fairness, making them binding.
  3. Court-Approved Contracts: Some jurisdictions allow courts to validate contracts involving minors, particularly in business or high-profile engagements.
  4. Banking and Insurance Agreements: Many states enforce contracts relating to bank accounts, insurance policies, or student loans when statutes authorize such transactions.

These categories often appear in minor contract law cases examples when courts assess whether a minor's contract should be upheld for fairness and necessity.

Frequently Asked Questions

1. Can a minor enter into any legally binding contract? Minors can enter into contracts, but most are voidable. Exceptions include contracts for necessaries or those court-approved.

2. What happens if a minor lies about their age when signing a contract? Even if a minor misrepresents their age, the contract is usually still voidable. However, restitution may be required depending on the jurisdiction.

3. How can a minor disaffirm a contract? A minor can disaffirm a contract through clear communication or actions showing intent to cancel. This must typically occur before or shortly after reaching the age of majority.

4. Are there any contracts a minor cannot void? Yes, contracts involving necessaries, military service, and sometimes employment or court-approved agreements cannot typically be voided.

5. What is an example of a minor contract law case involving employment? In Doyle v. Giuliucci, a minor athlete's contract was upheld due to its court-approved nature, demonstrating how employment contracts may bind minors under specific conditions.

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