Aetna Iron & Steel Co. v. Taylor

3 Ohio N.P. 152

This text of 3 Ohio N.P. 152 (Aetna Iron & Steel Co. v. Taylor) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aetna Iron & Steel Co. v. Taylor, 3 Ohio N.P. 152 (Ohio Super. Ct. 1895).

Opinion

PUGH, J.

The plaintiff is a foreign corporation, having been incorporated under the laws of the State of West Virginia. The business in which it is engaged being that of manufacturing iron and steel, is carried on at Bridgeport, Ohio.

April 23, 1893, the legislature passed an act which declared that no foreign corporation, other than a banking and insurance corporation, could do business in this State without first having procured from ihe Secretary of State a certificate that it has complied with the requirements of law to authorize it to do business in this State, and that its business is such that it can be lawfully carried on in this State. Any such corporation, failing to procure this certificate, is disabled from maintaining an action on any contract made in this State.

Before granting the certificate, the Secretary of State had to exact from the corporation a sworn copy of its charter, to be hied, and a statement disclosing the nature and object of its business which it proposes to carry on in this state the amount of its capital stock, its principal place of business, and the name of a person upon whom service of process could be made in this State according to the civil code, such person to have an office or place of business at the place where such corporation is to have its principal place of business.

For this certificate the corporation is required to pay a fee to the Secretary of State, graduated by the amount of its capital stock. The plaintiff’s capital stock being over one million, the fee was S50.00.

This statute did not purport to amend or supplement any pre-existing statute. The plaintiff paid the fee of 850.00.

On May 16, 1894, over a year after the passage of the other act, the legislature passed an act to further supplement section 148 of the Revised Statutes. By this act, commonly called the “Hard Law,” all foreign corporations, except insurance, banking and other corporations mentioned in the act, in the exception, incorporated for the purposes of profit, and which were then doing business or might thereafter do business in this State, and which owned or used part, or all, of their capital or plant in this State, should, within thirty days after the passage of the act, make a sworn statement, in such form as the Secretary of State might drescribe, showing: 1. The number of

shares of the capital stock and the par value of each share. 2. Name and location of the office or offices of the company in Ohio, and name and address of the officers and agents of the company in charge of its business in Ohio. 3. The value of the property owned and used by the company in Ohio, where situate and the value of the property owned and used outside of Ohio. 4. The proport’on of its capital stock which is represented fc.y property owned and used and by business transacted in Ohio.

From these facts, and such other facts as should come to his knowledge, bearing upon tae question, the Secretary of State had to determine the proportion of the capital stock represented by the company’s property and business in Ohio, and then charge and collect from the company for the privilege of exercising its franchise in Ohio one-tenth of one per cent, upon the proportion of its authorized capital stock, so represented by the property owned and used, and by its business transacted in Ohio.

It was declared that this was the same fee that was exacted from domestic corporations, and section 148a of the Revised Statutes does not impose upon domestic corporations a like tax.

Upon payment of this fee the Secretary of State was obliged to issue a certifiate to the foreign corporation certifying that it had complied with the laws of Ohio, and is authorized to do business therein. Against every foreign corporation which fails to comply with this act, penalties are denounced ; but every foreign corporation that complies with it is to be exempt from process of attachment on the ground that it was a foreign corporation, or a non-resident of the State.

This statute took no notice of the act of 1893.

The Secretary of State, in obedience to the statute of 1894, charged against and demanded from the plaintiff a fee of 85,000.00, which it paid under protest, and now, in this action, it seeks to recover it Dack.

It is insisted that the act of 1894 is unconstitutional, because it is retroactive and impairs the obligation of contracts, and because the tax imposed is not uniform upon all property.

Again, it is claimed that if the act is constitutional, only 82,000.00 could have been legally charged against the plaintiff.

The ground work of the first contention is the assumption that the act of 1893, and the payment of 1he 850.000 by the plaintiff constituted a contract; in consideration of the payment of that sum the plaintiff became entitled to do business within this State, either forever, or for a reasonable period, it is argued.

I am unable to perceive the distinction between these two statutes which the Attorney General contended does exist between them. There is no ingenuity in dialectics which can satisfy one that the main purpose of both of these acts is not the same, namely, that a fee shall be paid by foreign corporations for exercising their franchises in this State.

This purpose is declared in express terms by the act of 1894.

The fee of 850.00 was exacted by the act of 1893 as a fee for the Secratary of State, [154]*154filing the certificate therein prescribed. But obtaining-the certificate is a precedent .condition to.the right of the corporation doing business in the State. Therefore it is manifest that the $50.00 had to be pá'id as a fee for the exercise of’ the plaintiff’s corporate franchise in this State.

This construction compels the court' to squarely meet and decide the question whether is was competent for the legislature, at the expiration of one year, or a little over one year, after it granted the p iaintiff the right to do business in this State, for which it paid the sum of 850.00, whether it could increase the fee to be paid for a continuation of the permission to 85,000.00 or $2,000.00.

If there was a contract made between the State and 1he plaintiff at the time it paid the 850.00, the answer must be in the negative.

The plaintiff asserts that “upon the faith of such permit and authority, in the transaction of its said business, it has expended large sums of money in the improvement of its plant and made contracts with citizens of this State, which contracts are now subsisting, and upon which are now, or will become, due to it large sums of money, and which, in the event of non-performance by said citizens, are only enforcible by it in the courts and within the jurisdiction of this State.

This sounds like the plaintiff was relying upon that form of contract which consists of representations made by one party and acts done by another upon the faith of such representations. Yet I do not understand that plainitff’s counsol take that view. Their contention is that there was that form of contract which consists of an intentional offer on the one side and an intentional acceptance on the other side. In effect, the legislature said to the plaintiff: You may do business in this tate if you pay a fee of $50.00. This was a standing offer. Thereupon the plaintiff accepted it by paying the $50.00.

But the elements of a contract did not exist in the transaction between the State and the plaintiff.

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3 Ohio N.P. 152, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aetna-iron-steel-co-v-taylor-ohctcomplfrankl-1895.