Bank of Erie v. LaJohn

27 Pa. D. & C.2d 705, 1962 Pa. Dist. & Cnty. Dec. LEXIS 376
CourtPennsylvania Court of Common Pleas, Erie County
DecidedFebruary 16, 1962
DocketD.S.B. 887 and 888
StatusPublished

This text of 27 Pa. D. & C.2d 705 (Bank of Erie v. LaJohn) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Erie County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of Erie v. LaJohn, 27 Pa. D. & C.2d 705, 1962 Pa. Dist. & Cnty. Dec. LEXIS 376 (Pa. Super. Ct. 1962).

Opinion

Laub J.,

Plaintiff entered into judgment, by confession, two judgment notes signed by defendants who are husband and wife. Defendant, James LaJohn, Jr., has petitioned to open the judgments, thereby presenting us with a novel problem which we are called upon to dissolve at this time.

The facts are these: James LaJohn, Jr., and Judith M. LaJohn, his wife, executed two judgment notes in favor of plaintiff. Each note was in the identical amount of $3,000, but they were executed at different times. Approximately five-and-a-half months after the creation of the second note, James LaJohn, Jr., individually and doing business as J. & J. Tire Company, was adjudicated a bankrupt. Judith M. LaJohn was not involved in her husband’s bankruptcy proceedings [706]*706and has not been adjudicated a bankrupt at any time. On January 26, 1961, eight days after James’ adjudication, plaintiff entered the notes into judgment against both defendants but did not attempt execution thereon until October 27, 1961, when a writ of execution was issued directing the sale of real estate held by defendants as tenants by the entireties. James received his final discharge in bankruptcy November 7, 1961, and six days later petitioned to open the judgments on the ground that his bankruptcy discharge released him from liability and that the notes do not represent a valid indebtedness against him. A rule to show cause was entered and proceedings were stayed meanwhile.

Neither the petition nor the answer filed thereto supplies information whether the debts in controversy were duly scheduled by the bankrupt in time for proof and allowance, nor is there any allegation concerning notice or actual knowledge of the bankruptcy proceedings by plaintiff as required by section 17a(3) of the Bankruptcy Act of July 1, 1898,11 U.S.C.A. §35. It is, therefore, probable that the petition is insufficient in any event but, in view of the importance of the matter to those who lend money to husbands and wives on the strength of - the marriage relationship and in view of the importance of the matter to husbands and wives who own entireties property and need to borrow on its credit, we have concluded to treat the petition as though it contains all necessary averments.

The difficulty may be succinctly stated as follows: Where a husband and wife enter into the execution of a judgment note as a common obligation and thereafter the husband becomes bankrupt and is discharged in bankruptcy proceedings but the wife has not become bankrupt and is not so discharged, may the obligee of the judgment note enter it in judgment against both obligor’s- and thereafter successfully maintain the [707]*707judgment’s integrity? The answer depends, we think, upon the nature of the obligation and whether the bankruptcy court had jurisdiction to discharge it.

It is important at the outset to examine the theory and jurisdiction of bankruptcy proceedings to determine whether, apart from James’ individual liability, this was a debt which falls within their compass. Black’s Law Dictionary defines bankruptcy, inter alia, as “The proceedings taken under the bankrupt law, against a person (or firm or company) to have him adjudged a bankrupt, and to have his estate administered for the benefit of the creditors, and divided among them.” This means that the bankrupt can be absolved from the liability of his debts by throwing into the common pot for distribution to his creditors all of his property which is liable therefor. It is obvious that in this Commonwealth, where entireties estates are fully recognized, James LaJohn, Jr., could not subject to bankruptcy administration any entireties property held by himself and his wife. The Bankruptcy Act itself recognizes that, in those States where a tenancy by the entireties is permissible, the trustee cannot, except in certain instances, reach out and take any property held by the entireties for, in section 70(a) 11 U.S.C.A. 1110(a) there is this provision:

“All property ... in which the bankrupt has at the date of bankruptcy an estate or interest by the entirety and which within six months after bankruptcy becomes transferable in whole or in part solely by the bankrupt shall, to the extent it becomes so transferable, vest in the trustee ... as of the date of bankruptcy.”

It is obvious that the bankrupt could not have transferred in whole or in part any interest which he- had in the entireties property, either within six months after bankruptcy as the statute provides, or at any other time while the entireties estate remained intact. The incidents of an entireties estate in Pennsylvania [708]*708were adequately described in C. I. T. Corporation v. Flint, 333 Pa. 350, 5 A. 2d 126 (reiterated in Lunnen v. Hunter, 348 Pa. 402, 404-05, 35 A. 2d 292), where it was said:

“. . . Tenancy by entireties is a venerable institution of the common law; it rests upon instincts which form the very warp and woof of our domestic and social fabric. In such a tenancy each spouse is seized per tout et non per my. There is but one legal estate, which, by a long course of judicial decisions, has been buttressed against inroads attempted either by the parties themselves or by their individual creditors.”

In such an estate, the parties each own the whole or the entirety and not a share, moiety or divisible part: Gallagher Estate, 352 Pa. 476, 478, 43 A. 2d 132. They are not joint tenants or tenants in common. As a consequence of owning the entirety, neither party can dispose of any part without the consent of the other, but the whole must remain to the other: Meyer’s Estate (No. 1), 232 Pa. 89, 94, 81 Atl. 145. Thus, the trustee had no vested right in any entireties property held by James La John, Jr. “A trustee in bankruptcy of the husband is not entitled, during the life of the wife, to any part of the principal or income of the [entireties] estate . . . the husband and wife can convey the property free from judgments and the effect of bankruptcy proceedings against the husband and also from any contingent interest or ownership by the trustee in bankruptcy in the event of the husband surviving the wife . . .”: C. I. T. Corporation v. Flint, supra.

It is clear, therefore, that the bankruptcy court could not force defendants’ entireties property into the bankrupt’s estate for distribution among the husband’s creditors, but this is only a halfway station in the road to a solution of the entire problem. Conceding [709]*709that the trustee could not take possession of the entireties property of defendants, what can be said of the debts themselves? Were the debts discharged notwithstanding the entireties property could not be made to apply to them? The answer to these inquiries must be found in the nature of the debts which defendants created.

It may be stated at once that, in view of the statutes which emancipate married women, there can be no question but that the debts were joint and several. In Pennsylvania, a married woman may sue and be sued with the same effect and results and consequences as an unmarried person (48 PS §111) and she may own, control, use and convey property of any kind in the same fashion as a married man (48 PS §32.1). It seems apparent that, because of these acts, execution may be levied against a married woman’s individual property for her obligations to the same extent as an action may be had against the property of any other individual and that, therefore, a married woman may legally enter into a joint and several obligation with her husband or anyone else.

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

Related

Swope v. Turner
163 A.2d 714 (Superior Court of Pennsylvania, 1960)
First Nat. Bank of Goodland v. Pothuisje
25 N.E.2d 436 (Indiana Supreme Court, 1940)
Edwards & Chamberlin Hardware Co. v. Pethick
230 N.W. 186 (Michigan Supreme Court, 1930)
McPherson v. Gregory
260 N.W. 767 (Michigan Supreme Court, 1935)
Wharton v. Citizens Bk. of Bosworth
15 S.W.2d 860 (Missouri Court of Appeals, 1929)
Gallagher Estate
43 A.2d 132 (Supreme Court of Pennsylvania, 1945)
Lunnen v. Hunter
35 A.2d 292 (Supreme Court of Pennsylvania, 1943)
C. I. T. Corporation v. Flint
5 A.2d 126 (Supreme Court of Pennsylvania, 1939)
Cake v. Cake
43 A. 971 (Supreme Court of Pennsylvania, 1899)
Meyer's Estate
81 A. 145 (Supreme Court of Pennsylvania, 1911)

Cite This Page — Counsel Stack

Bluebook (online)
27 Pa. D. & C.2d 705, 1962 Pa. Dist. & Cnty. Dec. LEXIS 376, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-erie-v-lajohn-pactcomplerie-1962.