Martinez v. Del Valle: 1877

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Martinez v. Del Valle: 1877

Plaintiff: Eugenie Martinez
Defendant: Juan Del Valle
Plaintiff Claim: That Del Valle broke his promise to marry the plaintiff
Chief Defense Lawyer: Joseph H. Choate
Chief Lawyer for Plaintiff: William H. Beach
Judge: Donohue (historical records do not indicate first name)
Place: New York, New York
Date of Trial: 1877 January Term
Decision: Jury verdict in favor of the plaintiff for damages of $50

SIGNIFICANCE: The famous lawyer Joseph Choate represented Juan Del Valle, and his handling of Eugenie Martinez on the witness stand has been hailed as a model of the art of cross-examination.

Juan Del Valle was a wealthy businessman from Cuba who had established himself in New York City. He had divorced his first wife and was well into middle age when he met a dark-haired Spanish beauty in her early 20s named Eugenic Martinez. On January 14, 1875, Martinez slipped while walking on an icy sidewalk and sprained her ankle. Del Valle happened to be nearby, and he helped her up and took her home.

According to Martinez, Del Valle visited her the next day to see how she was recovering. Del Valle became her regular suitor and, after only three weeks of courtship, allegedly promised to marry Martinez but reneged after an "engagement" of several months. Martinez sued Del Valle for $50,000 in damages for breach of promise of marriage.

It was rumored that Del Valle offered Martinez $20,000 to settle out of court and avoid a scandal, but she refused. Martinez was represented by William H. Beach, and Del Valle was represented by Joseph H. Choate. With Judge Donohue presiding, the case was tried in the New York City Court's 1877 January Term. Because Del Valle was a rich man and Martinez's family was poor, the press labeled Martinez a "goiddigger" and the case attracted considerable publicity.

Choate was a famous lawyer, known for his verbal skills and scathing comments. From start to finish he stole the show. Choate encouraged the public's low opinion of Martinez when he referred to her case:

Never did a privateer upon the Spanish Main give chase to and board a homeward bound [ship] with more avidity and vigor than this family proposed to board this rich Cuban and make a capture of him.

Choate Cross-Examines Martinez

Beach's principal witness was Martinez herself, and he had her relate the entire story to the jury. A key element of Martinez's case was her claim that, when Del Valle proposed to her three weeks after they met, he took her to a jewelry shop and bought her a ring as a token of his sincerity. Del Valle claimed he bought Martinez the ring the day after they met, and not as a promise of marriage but merely out of affection for a young lady in distress that he had helped. As proof that Del Valle's version of the story was the true one, Choate had arranged for the jeweler to be available to testify that the ring was purchased on January 15. First, however, Choate would let Martinez perjure herself under oath.

Choate began by allowing Martinez to claim that, because of her sprained ankle, she didn't leave her house for five days after her fall.

Question: How long was it before you got entirely over it so as to be able to go out of doors?
Answer: Well, I went out the fifth day.
Question: And not before?
Answer: And not before.
Question: So that because of the injuries that you sustained, you were confined to the house for five days?
Answer: I was.

Next, Choate got Martinez to commit herself to her claim that she went to the jewelry store with Del Valle three weeks after they met.

Question: Some considerable number of weeks, you say, intervened between your first acquaintance [with Del Valle] and … the giving of the ring?
Answer: About three weeks as nearly as I can fix the time.

Choate now had Martinez on record as testifying that she did not leave her house for five days following her January 14 fall and that Del Valle bought her the ring three weeks after they met. Choate continued to cross-examine Martinez at length on some other issues to raise skepticism in the minds of the jurors about her story, so that once he revealed her lies her credibility would be completely destroyed. For example, Choate questioned Martinez about her claim that Del Valle's courtship included many long, intimate meals at a popular restaurant called Solari's.

Question: How long were these [meetings] at Solari's: these meetings when you went there and had a private room generally?
Answer: They varied in length. Sometimes we arrived there at 2:00 and remained until 4:00, sometimes we arrived there a little earlier.
Question: About a couple of hours?
Answer: Two or three hours.
Question: What were you doing all that time?
Answer: We were eating.
Question: What, not eating all the time?
Answer: Eating all the time.
Question: Two hours eating! Well, you must have grown fat during that period!
Answer: Well, perhaps you eat much quicker than I do.

After Martinez's cross-examination, Choate put the jeweler on the witness stand. The jeweler testified that Martinez and Del Valle were in his shop on January 15, the day after the fall. Further, the jeweler had made an entry in his account books showing that the purchase was made on the 15th.

The jeweler's testimony proved that Eugenie Martinez had lied about being unable to leave her house for five days and about the purchase date of the ring. Her credibility was further shaken by Choate's expert cross-examination, which brought every weakness and hard-to-believe aspect of her story to light. If it hadn't been for Choate's skill, the jury might have taken the obvious signs of Del Valle's affection for Martinez as evidence of a promise of marriage regard-less of when the ring was bought. Instead, while the jury returned a verdict in Martinez's favor, it gave her only $50 in damages, far short of the $20,000 Juan Del Valle had been willing to pay to avoid a scandal.

—Stephen G. Christianson