## Facts

- A mother sued a man for damages arising from the alleged seduction of her minor daughter, who lived under the mother’s care and control.
- The mother’s claim proceeded on the common-law theory that she was entitled to the daughter’s services and could recover for their loss.
- The mother sought to prove that the seduction caused sickness or impairment of the daughter’s health, making the daughter unable to render services and causing related loss to the mother.
- The trial court excluded evidence that the seduction caused injury to the daughter’s health, treating recoverable harm as limited to pregnancy or venereal disease (or similar conditions).
- After excluding that evidence, the trial court directed a verdict for the defendant.
- The mother appealed.

## Issues

1. Whether a parent may recover, in a loss-of-services action based on the seduction of a minor child, for illness or impairment of health proximately caused by the seduction.
2. Whether the trial court erred by excluding evidence of health-related injury and directing a verdict for the defendant on the ground that only pregnancy or venereal disease supports recovery.

## Decision

- The Supreme Judicial Court held the trial court’s limitation of recoverable harm to pregnancy or venereal disease was erroneous.
- The court ruled that a parent may recover for sickness or injury to the child’s health, and resulting loss of services, when proximately caused by the seduction.
- The exclusion of evidence of health-related injury was reversible error because it prevented proof of a compensable loss of services.
- The directed verdict for the defendant was set aside, and the case was remanded for further proceedings.

## Legal Principles

- In a parent’s seduction action framed as loss of a minor child’s services, damages may include illness or impairment of health caused by the wrongful conduct and the resulting deprivation of services.
- Recoverable harm is not confined to seduction outcomes such as pregnancy or venereal disease; other physical or health consequences are compensable if causally connected.
- Evidence is admissible if it tends to show that the defendant’s conduct proximately caused the child’s sickness and the parent’s consequent loss of services (and related expense).

## Conclusion

The court rejected a narrow rule limiting parental recovery to pregnancy or venereal disease and held that a mother may prove and recover for seduction-caused illness that diminishes her minor daughter’s services, requiring a new trial under the correct damages standard.


Abrahams v. Kidney, 104 Mass. 222 (Mass. 1870)