Arney v. Brittain & Co.

185 Iowa 1114
CourtSupreme Court of Iowa
DecidedApril 14, 1919
StatusPublished
Cited by1 cases

This text of 185 Iowa 1114 (Arney v. Brittain & Co.) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arney v. Brittain & Co., 185 Iowa 1114 (iowa 1919).

Opinion

Evans, J.

The defendant corporation ivas the owner of a packing plant, situated at Marshalltown, Towa. On February 25, 1915, it sold the same by written contract to one David Naylor and R. F. Hall, for a consideration of $92,250, to be paid as follows: $10,000 on June 15, 1915, and the balance of the purchase price on or before six months from the date of the contract. Naylor and Hall were without capital, and paid nothing on the contract at the time of its execution. They were promoters. After acquiring the [1116]*1116contract, they proceeded to organize a new corporation, as a purchaser of the plant in question. They came to Marshall-town, and interested many prominent business men in the enterprise. In form, at least, they organized a corporation with a capital stock of $400,000, intending to sell the stock thereof to the citizens, of Marshalltown and vicinity. This organization was had on April 22, 1915. On May 4, 1915, the directors of the new corporation, one of whom was Hall, entered into a contract with Naylor, whereby it purported to purchase the plant in question for $170,000. It also entered into a contract to pay Naylor a commission of 12% per cent for the sale of the stock of the new corporation. The evidence shows that many of the stockholders and directors understood from Naylor that $170,000 was the option price for which he obtained the contract. There was much dissatisfaction on the part of proposed stockholders and directors as to the rate of commission exacted by Naylor. The earlier meetings of the directors were stormy. The personnel of the directorate changed rapidly, by successive resignations. Some evidence tends to show sinister manipulation and control of the acts of the directors by Naylor and Ball.

Under the contract between Naylor and the new corporation, $10,000 was to be paid Naylor on June 10th. The same amount was to be paid by Naylor to the defendant corporation on June 15th. On June 14th, the directors ordered that the amount thus due Naylor should be paid, by the issue of checks payable to the defendant corporation. Two such checks, of $8,000 and $2,000 respectively, were issued, and duly signed by the vice-president and the treasurer, the ¡(resident having resigned, and the same were delivered to Naylor, who delivered them to the defendant company, in payment of the amount due from him on liis contract. These are the funds which the plaintiff seeks to recover. The argument in its behalf is that Naylor, as a promoter, sustained a fiduciary relation to the corporation which he organized; [1117]*1117that he obtained his contract from the new corporation by fraudulent concealment and representation; and that the defendant corporation, at the time it received the checks in question, knew of the fraud thus practiced, or at least knew such facts as charged it with knowledge of the fraud. It is also argued that the officers and directors of the company were illegally elected, and that they were without title to their respective offices as mere usurpers, and that all their acts were wholly void. It is also argued that the defendant company had knowledge of such lack of authority.

l. Corporations : promoter :Wlth dics. ' lcmo Without going into undue details of the evidence, there is much in the record tending to show gross fraud on the part of both Naylor and Hall in their dealings with the organization of the new company, and in ac-(miring their contracts therewith. If Naylor obtained his contract by fraudulent representations or concealment, the corporation could repudiate it, upon discovery. It could sue Naylor for damages or for an accounting; or it could rescind the contract, and recover the $10,000 paid. In that event, it could also recover such amount paid to any third party who had wrongfully received the same, with notice of the fraud; and such is a large part of the argument for appellant. The trouble we find at this point is that the argument is at variance with the petition. The petition was not predicated upon the theory of fraud on the part of Naylor or Hall. There is no allegation that the contract of Naylor was obtained by fraud; nor any allegation that such contract with Naylor was ever rescinded or repudiated. Indeed, there was no reference in the petition either to Naylor or to Hall, or to the contract pursuant to which the checks in controversy were paid. The petition was predicated upon the theory that the officers who purported to act for the new corporation were not such cíe jure, because [1118]*1118of illegality in their selection; and that the defendant knew of such illegality.

2. corporations : remoter; If, under the pleadings and the evidence, we were warranted in finding fraud on the part of Naylor in obtaining such contract, this would render the contract voidable only, and not void. It would rest in the election of the corporation to rescind it. It is urged in argument that the beginning of the suit is a sufficient act of rescission. But Naylor is not a party to the suit. If rescinded, it must be so rescinded as to Naylor. There is nothing in the petition or the evidence to warrant a finding that such rescission was had.

We turn away from the question of fraud, therefore, and proceed to consider the case upon the theory of the petition.

Were the check and the delivery thereof to the defendant corporation rendered invalid, in that the officers issuing the same were elected irregularly or illegally, and in that the defendant corporation received the same without consideration ?

3. Corporations : contracts with promoter: consideration : acceptance of check. On the question of lack of consideration, the argument is that there were no contractual relations between the .two corporations; that the plaintiff corporation owed nothing to the defendant; that the defendant, therefore, parted with nothing, and the plaintiff got nothing. The argument is not quite sound. Disregarding the question of fraud, as we must, the plaintiff corporation was bound by a contract, good on its face for the payment of f10,000 on the tenth day of June. It knew that it could not acquire a good title to the packing plant from Naylor until Naylor had acquired it from the defendant. It had an indirect interest, therefore, in insisting that the money paid by it to Naylor should be applied by Naylor toward the acquisition of the property. The acceptance by Naylor of these checks payable to the defendant company was an ac[1119]*1119ceptance of them as payment of the amount due him under his contract. The plaintiff company was entitled to claim credit accordingly. The acceptance of these checks by the defendant company from Naylor was an acceptance of them as payment of the amount due from him to it on June lEith. As to the mere question of consideration, therefore, there was no lack.

4' offieers^e^ncio • tMranpSersons. On the question of the defect of title to office of the officers of the plaintiff corporation, we are confronted with the fact that they were de facto officers. Each of them was in possession of his office and exercising its f,nu;tions, and no one contended with him. what the rights of these de faoto officers might be as between them and the corporation, or as between them and its stockholders, or as between each other, we have no occasion to consider. The defendant corporation, which was the payee of the checks, was a third party.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kilts v. American Legion Okoboji Lakes Post 654
581 N.W.2d 189 (Court of Appeals of Iowa, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
185 Iowa 1114, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arney-v-brittain-co-iowa-1919.