Allen v. Sinning

8 Ohio N.P. (n.s.) 201
CourtCourt of Common Pleas of Ohio, Hamilton County
DecidedFebruary 15, 1909
StatusPublished

This text of 8 Ohio N.P. (n.s.) 201 (Allen v. Sinning) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Hamilton County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Sinning, 8 Ohio N.P. (n.s.) 201 (Ohio Super. Ct. 1909).

Opinion

Gorman, J.

Heard on demurrer to answer and cross-petition.

The causes of action set out in the petition are first, upon four promissory notes aggregating $2,100; and secondly, a foreclosure of a certain real estate mortgage given to secure said notes by the defendants to the plaintiffs, which real estate is described in the second cause of action.

The defendants answer, admitting all the allegations of the petition.

[202]*202By- way of cross-petition against the plaintiffs the defendants set up that on August 22, 1908, they entered into a contract with one Mary A. Hampton to sell to her the premises described in the petition upon certain terms (not set out in the cross-petition) involving an exchange of real estate rand certain cash considerations, and as a part of said agreement for a sale and exchange of property, said Mary A. Hampton was to assume one of said notes described in the petition for $500 and another of the notes for $600 described in the petition, and that after said sale and exchange of property with Mary A. Hampton, defendants intended to pay off the notes described in the petition as they became due, thereby completely satisfying the obligations set out in the petition; that in part performance of said contract between defendants and said Mary A. Hampton, she took possession of said farm, the premises described in the petition, and that defendants obtained a loan for said Mary A. Hampton on her property (presumably not the property described in the petition) to enable her to carry out her contract with the defendants; that afterwards, on or about October 23, 1908, Mary A. Hampton refused to carry out the terms of her contract, and defendants are informed and believe that the reason for her said action and breach of contract with defendants was that plaintiffs in this case, George E. Allen and Ida A. Allen, falsely, maliciously and with intent to injure these defendants, stated that the title of defendants to said property was not good.

Defendants further aver that they were informed and believe that the object of plaintiff’s act in slandering their title to said farm was to prevent defendants from making a sale and exchange of said farm, and thereby preventing defendants from paying the notes owing to plaintiffs, so that the plaintiffs might bring the foreclosure suit against defendants and obtain the farm back at a small price. Defendants say that their title to said property is'a good title and that the only incumbrance upon it is the mortgage described in the petition which the said Mary A. I-Iaiupton knew of at the time of entering into her contract of sale and exchange of property with defendants.

Defendants further aver that they have not been able to dispose of said property and that they have been specially damaged [203]*203by tbe action of tbe plaintiffs in tbe sum of $1,500, and that they are entitled to punitive damages for tbe malicious, barmful and slanderous acts of tbe plaintiffs in tbe sum of $600, and they pray for judgment on tbeir cross-petition in the sum of $2,100, which they ask may be set off against plaintiffs’ claim.

Plaintiffs have filed a demurrer to this cross-petition on tbe ground the allegations thereof do not state a cause of action against tbe plaintiffs.

Counsel for defendants urge that the averments of tbe cross-petition constitute slander of title of defendants’ property, whereby they suffered tbe damages resulting from a loss of the sale of the property to said Mary A. Hampton, all on account of tbe false and malicious words of the plaintiffs, and, in support of their contention, they cite Newell on Libel and Slander, page 203, where the doctrine is laid down that defamation of one’s title to property, real or personal, is actionáble upon the same principles of law that render defamation of character actionable; and it seems to be now well settled that an action* will lie for falsely and maliciously making an oral or wjitten statement in disparagement of a person’s title to property or a property right, which results in causing the owner special damage. Burkitt v. Griffith, 90 Cal., 536; Newell on Libel and Slander, pages 203-208; Foulkard’s Starkie on Slander and Libel, p. 201.

The gravamen of the action, as in slander of the person, is the uttering of the false and malicious statement in disparagement of the title to the property. Pater v. Baker, 3 C. B., 868; Malachy v. Soper, 3 Bing. N. Cas., 382; Wilson v. Dubois, 35 Minn., 473; Meyrose v. Adams, 12 Mo. App., 331.

In respect to real property, where' the false and malicious statement is that the plaintiff has no title of which he is the ostensible'owner, or that his title is defective, and the assertion results in special damage to the plaintiff, an action for slander of title can be maintained. Dodge v. Colby, 108 N. Y., 445.

There is no reported case in Ohio of an action of this character that the. court has been able to discover after a diligent search, and therefore the right to maintain the cause of action set up in the cross-petition herein must be determined on principle and the authorities outside of this state.

[204]*204While it is well settled that an action, for slander of title to real estate resulting in special damage to the owner thereof will lie, nevertheless, where the words constituting the slander of title result in a purchaser’s breaking his contract of purchase (as is averred in the case at bar) .ivilh the owner of the property, it is-not definitely settled that the action can be maintained; but the weight of authority appears to support the rule that in such a case the remedy of the owner is against the defaulting purchaser for breach of contract, or to compel the specific performance of the contract,- and that he can not maintain an action for slander of title; the chief reason given for this rule being that the injured party can recover full satisfaction in an action against the defaulting purchaser, and that the latter (the purchaser) may perhaps have his remedy over against the slanderer of the title. Brentman v. Note, 3 N. Y. Supp., 420; Burkitt v. Griffith, 90 Cal., 533; Walkley v. Bostwick, 49 Mich., 374; Paull v. Halferty, 63 Pa. St., 46.

If the right to maintain this action on the cross-petition be claimed to be grounded, not on slander of title, but on the principle of interference with contract relations, as a specific tort, which doctrine is of recent origin, we must consider whether or not it is one of those contracts for which an action will lie on account of a wrongful and malicious interference with contract relations.

The -early common-law gave a remedy in damages for interference with contract relations only when the contract was one between master and servant. Lumley v. Gye, 2 El. and Bl., 216.

This view is still vigorously maintained in many American jurisdictions. Boyson v. Thorn, 98 Cal., 578; Chambers v. Baldwin, 91 Ky., 121; Glencoe, etc., Land Co. v. Hudson Bros., 138 Mo., 439; McCann v. Wolff, 28 Mo. App., 447.

But the more advanced and fully developed doctrine now prevailing in this country is thus stated’ by Justice Brewer, of the United States Supreme Court:

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Related

Dodge v. . Colby
15 N.E. 703 (New York Court of Appeals, 1888)
Jones v. . Stanly
76 N.C. 355 (Supreme Court of North Carolina, 1877)
Chipley v. Atkinson
1 So. 934 (Supreme Court of Florida, 1887)
Lundine v. Callaghan
82 A.D. 621 (Appellate Division of the Supreme Court of New York, 1903)
Boyson v. Thorn
21 L.R.A. 233 (California Supreme Court, 1893)
Brentman v. Note
3 N.Y.S. 420 (City of New York Municipal Court, 1889)
Heckman v. Swartz
12 N.W. 439 (Wisconsin Supreme Court, 1882)
Meyrose v. Adams
12 Mo. App. 329 (Missouri Court of Appeals, 1882)
Chambers & Marshall v. Baldwin
11 L.R.A. 545 (Court of Appeals of Kentucky, 1891)
Walkley v. Bostwick
13 N.W. 780 (Michigan Supreme Court, 1882)
Helwig v. Lascowski
10 L.R.A. 378 (Michigan Supreme Court, 1890)
Wilson v. Dubois
29 N.W. 68 (Supreme Court of Minnesota, 1886)
Glencoe Land & Gravel Co. v. Hudson Bros. Commission Co.
36 L.R.A. 804 (Supreme Court of Missouri, 1897)
McCann v. Wolff
28 Mo. App. 447 (Missouri Court of Appeals, 1888)

Cite This Page — Counsel Stack

Bluebook (online)
8 Ohio N.P. (n.s.) 201, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-sinning-ohctcomplhamilt-1909.