Massachusetts Supreme Judicial Court September 15, 1820 (Sikes v. Johnson)

The cases cited to the contrary (1) relate to civil acts, done by the command of persons not having capacity to make contracts; and because such commands are in the nature of a contract, they are void. But trespasses are analogous to crimes, which femes covert and minors may be answerable for, although not personally present at the commission of them (2), (3).

Chitty on Pleading, 65—67.—Co. Lit.