## Facts

- Charles A. Ryder and Edith C. Ryder, husband and wife, stayed as guests at the Jefferson Hotel in early October 1921 (Charles first; Edith arrived later).
- They alleged a contract for hotel accommodations and the usual duties arising from the innkeeper–guest relationship.
- Late at night, S. J. Bickley, acting as the hotel’s servant and agent, knocked at their door, spoke rudely, and accused Edith of not being Ryder’s wife, implying immoral conduct.
- The Ryders alleged they were compelled to leave the hotel around midnight and find other lodging.
- They alleged the conduct injured their reputations, credit, and business; Charles also alleged loss of customers and profits.
- They filed one joint action against the hotel company and Bickley, seeking a single undivided $10,000 recovery.

## Issues

1. Whether the spouses’ asserted contract and tort claims reflected joint rights and a joint injury permitting a single joint action for joint damages.
2. Whether, on the face of the complaint, the alleged wrongs were personal to each plaintiff and therefore several, making joinder in one undivided claim improper.

## Decision

- The South Carolina Supreme Court reversed the order overruling defendants’ demurrer.
- The court held the pleaded causes of action were several, not joint, because the alleged personal wrongs and resulting damages were individual to each spouse.
- Because the complaint sought one joint recovery for legally separate injuries, it improperly united distinct causes of action and was subject to demurrer.
- Dissent: one justice would have treated the alleged accusations and expulsion as a joint injury directed at the marital relationship, permitting a joint action.

## Legal Principles

- Personal torts committed against multiple persons generally create separate rights of action for each injured person; joint suit is permitted only in limited special situations involving a legally recognized joint right or joint injury.
- Marriage alone does not convert individual personal tort claims into a joint cause of action absent a recognized claim for injury to the marital relationship.
- When plaintiffs’ rights and damages are several, a pleading that demands an undivided joint award is defective and may be challenged by demurrer for misjoinder and improper joinder of causes.

## Conclusion

The court required separate treatment of the spouses’ claims because the complaint alleged individual personal wrongs and individualized damages, making a single joint action for a lump-sum recovery procedurally improper.


Ryder v. Jefferson Hotel Co., 121 S.C. 72, 113 S.E. 474 (S.C. 1922)