Can a Father Be Held Liable for the Neglience of His Non-Dependant Self-Supporting Adult Son Living at Home With Parents ?
In Hubert v. Harpe, 181 Ga. 168, 172-173 (182 S.E. 167) (1935) the Supreme Court held that a father could be held liable under the family purpose doctrine for the negligence of his adult son who was "non-dependent" and "self-supporting," but lived at home with his parents without paying board.
The fact that the son was an adult was irrelevant to the family purpose analysis.
Likewise, in Kennedy v. Manis, 46 Ga. App. 808, 809-810 (169 S.E. 319) (1933) the Court held that an "adult daughter, single and living at the home of her father and a member of his family," could fall within the scope of the family purpose doctrine.
In reaching that conclusion, the Court quoted with approval the following passage from the opinion of a Nebraska court:
"Where a son living at home with his parents is supported there, and is subject to parental control as a member of the family, the fact that he is over twenty-one years of age does not alter the rule that a father furnishing an automobile for the pleasure of his family is liable for the negligence of the son while driving it for his own pleasure." Id. at 810, quoting Linch v. Dobson, 108 Neb. 632 (188 N.W. 227) (1922).