## Facts

- Michael C. Beattie drove a 1991 Oldsmobile Cutlass on Route 1 near Milford, Delaware, and collided with the rear of a slow-moving truck performing weed-spraying operations on the median.
- Margaret S. Beattie, Michael’s wife, was a passenger in the car at the time of the collision.
- Margaret sustained catastrophic injuries that left her a quadriplegic, with medical expenses exceeding $286,000.
- Margaret filed a negligence action against Michael seeking damages for her personal injuries.
- At the time of the accident, Michael had substantial automobile liability insurance coverage.
- Despite the lawsuit, the parties remained married and reported no plans to divorce.

## Issues

1. Whether Delaware’s common-law doctrine of interspousal immunity, which bars one spouse from suing the other in tort, remained a valid rule that required dismissal of a spouse’s negligence claim for personal injuries.

## Decision

- The Delaware Supreme Court reversed the Superior Court’s summary judgment for the husband.
- The court abrogated the common-law doctrine of interspousal immunity in Delaware tort law and overruled prior Delaware precedents applying the doctrine.
- The case was remanded to the Superior Court for further proceedings consistent with the decision, permitting the wife’s negligence action to go forward.

## Legal Principles

- Interspousal immunity in tort is not preserved when its traditional rationales no longer justify a categorical bar to recovery for personal injuries between spouses.
- Concerns about preserving marital harmony do not warrant denying an injured spouse a remedy, particularly where serious injury and resulting financial burdens may strain a marriage more than litigation would.
- The possibility of collusion or fraud in intrafamily tort claims does not justify immunity as a matter of law; the adversarial process and insurer participation provide tools to test credibility and detect fraudulent claims.
- The widespread presence of liability insurance is a practical factor supporting abolition because many intrafamily tort suits seek recovery from coverage rather than from family assets.
- As a judge-made common-law rule, interspousal immunity is subject to judicial revision; stare decisis does not require retention of a doctrine that has become unjustified under modern conditions.

## Conclusion

The Delaware Supreme Court eliminated interspousal tort immunity and held that a spouse may maintain a negligence action against the other spouse for personal injuries, allowing the wife’s claim to proceed on remand.


Beattie v. Beattie, 630 A.2d 1096 (Del. 1993)