Joanna Boyle, acct. 17276

Additional Information

Joanna Boyle and her husband Terrence started a millenary (ladies’ hat) shop in 1855, a month after they got married. Terrence had come to America from County Armagh in 1849 and in February 1855, at age thirty-eight, he married Joanna Condon, sixteen years his junior and the American-born child of Irish immigrants. She had worked as a milliner before they met, and a month after their marriage Terence rented a storefront at 106 Eighth Avenue (just north of 15th Street) so she could open a hat shop. Johanna spent $300 on raw materials to make her initial stock of hats and bonnets, using $100 she brought to the marriage plus $200 in credit secured in her own name. She proudly hung a sign outside the shop that read “Mrs. Boyle’s Millinery.”

The hat shop was very profitable, and after a few months Terrence made the shop his full-time avocation as well.  He traveled around town buying the necessary raw materials from dry goods dealers and handled the finances, while Joanna made the hats, supervised the milliners they eventually hired to keep up with demand, and waited on customers.

When Terrence died in 1862, Joanna and Terrence’s brother Richard Boyle fought over the $1,000 in gold coins that the couple had bought with the profits from the hat shop (the attached article from the New York Transcript from 1864 provides the details of the case). Joanna claimed the coins were hers, but Richard’s lawyer argued that by law all profits from a business run by a married couple belonged to the husband. The court ordered an inventory of the Boyle’s property, which details the profits from their hat business that they had deposited in various New York banks since 1855:

In the name of Terrence Boyle:

Bowery Savings Bank        $   500

Emigrant Savings Bank      $5,550

German Savings Bank       $   500

Greenwich Savings Bank   $   450

Irving Savings Bank          $  500

Manhattan Savings Bank   $   500

Mariners’ Savings Bank      $   530

New York Savings Bank     $   522

Seamen’s Savings Bank    $   400

Sixpenny Savings Bank      $   400

TOTAL                                   $9,852

In the name of Joanna Boyle:

Bleecker Savings Bank       $   499

Emigrant Savings Bank      $   500

Seamen’s Savings Bank    $   500

TOTAL                                   $1,499

            In the lawsuit, the court ruled that all profits that a husband and wife made in business together legally belonged to the husband only.  Even profits Joanna put in the bank in her name only were legally Terrence’s, and when he died, he could will them to whomever he pleased. The court stated that if the Boyles had started their business after the spring of 1860, when the New York State legislature passed a married woman’s property law that required husbands to share the profits of jointly run businesses with their spouses, then Joanna could have claimed half the profits. The gold coins were therefore awarded to Terrence’s estate, whose executor was Richard, rather than to Joanna.  She was lucky that Terrence had bequeathed most of their bank accounts to her. But the outcome of the case showed that the legal standing of married female business owners was precarious.

            Note that most documents spell Joanna’s name “Johanna,” but she spelled it “Joanna,” so that is the spelling we have adopted.