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Rohrscheib v. Helena Hospital Ass'n
Citations: 12 Ark. App. 6; 670 S.W.2d 812; 1984 Ark. App. LEXIS 1557Docket: CA 83-305
Court: Court of Appeals of Arkansas; June 6, 1984; Arkansas; State Appellate Court
Emma Trainer was admitted to Helena Hospital on January 20, 1982, where an In-Patient Admission Form was created, listing her details but lacking any financial obligations or charges. The form referred to a 'responsible party' without defining their responsibilities, and it was not signed by Trainer. On January 25, 1982, after incurring over $4,000 in charges, her brother-in-law, J.D. Rohrscheib, visited her and later signed the admission sheet as 'responsible party' after paying a $200 ambulance deposit. The document he signed contained minimal information and did not explicitly state any financial obligations. The hospital later sued Rohrscheib for $4,239.16, claiming his signature made him a guarantor for Trainer's hospital bills. However, Rohrscheib contested this, asserting he believed he was only agreeing to be responsible for her safe transport, not for the hospital charges, and argued that the claim was barred by the Statute of Frauds. Testimony indicated that he was informed he was assuming responsibility for the charges, despite the total amount not being known at the time of signing. The trial court ruled against Rohrscheib, finding he had assumed financial responsibility based on the admission form. However, this decision was deemed erroneous because the form did not contain a clear promise to pay any debt, and the reliance on parol evidence to support the claim violated the Statute of Frauds, which requires such obligations to be in writing and signed. The court's interpretation was challenged as it did not adhere to the statutory requirements governing collateral promises. An original undertaking to obtain benefits and a promise to discharge a preexisting debt based on new consideration are enforceable and not subject to the statute of frauds. For a guaranty contract to be valid, it must include sufficient legal consideration, which can be a benefit to the debtor or guarantor, or a detriment to the guarantee. A promise to pay an existing debt without consideration is void. In this case, neither Mrs. Trainer nor Rohrscheib received any benefit from the signing of the document, nor did the hospital incur any detriment. At the time of signing, all charges had already been incurred, and there were no services rendered afterward based on an oral promise from Rohrscheib. Moreover, the hospital would have allowed Mrs. Trainer to leave regardless of Rohrscheib's signature. The court reversed and dismissed the case, with judges Cooper and Cloninger concurring.