Beaver's Administrator v. McGrath

50 Pa. 479, 1865 Pa. LEXIS 191
CourtSupreme Court of Pennsylvania
DecidedJune 29, 1865
StatusPublished
Cited by2 cases

This text of 50 Pa. 479 (Beaver's Administrator v. McGrath) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beaver's Administrator v. McGrath, 50 Pa. 479, 1865 Pa. LEXIS 191 (Pa. 1865).

Opinion

The opinion of the court was delivered, by

Read, J.

Partners are liable jointly at law for the debts and engagements of the firm, but in equity their liability is not only joint but several, except under special circumstances. This liability, as between thdmselves, they can modify and limit by contract, but it is not settled in this state how far they can limit their liability to third persons.

In Hess v. Werts, 4 S. & R. 356, where the suit was oh a promissory note issued by an unincorporated banking institution, romising to pay to bearer on demand one dollar out of their joint funds according to their articles of association, Judge Gibson said (p. 861), “ It is a general principle that partners are liable to third persons as for a personal debt. It is not merely the stock bring into the partnership that is hazarded, but they are responsible to the extent of their individual fortunes, and such responsibility cannot be limited by any proviso in the articles of partnership or agreement between themselves. But I see no reason to doubt but they may limit their responsibility by an express stipulation, made with the party with whom they contract, and clearly understood by him at the time. But this is a stipula[483]*483tion so unreasonable on the part of the partnership and affording such facility to the commission of fraud that, unless it appear unequivocally plain from the terms of the contract, I will never suppose it to have been in the view of the parties. Unless the contrary clearly appeared I would not suppose any one so imprudent as to contract solely on the credit of a fund exclusively within the control of another, and of the solvency of which he could not command the means of obtaining a knowledge. The management of it, and whether at the day of payment it will be sufficient, must necessarily be a secret known only to the partners themselves.”

Judge Duncan said (p. 365), “ On the second question, the personal responsibility, I know not any power but that of the legislature that can create a corporation; yet, if these associations can contract debts without a personal responsibility, payable only out of their joint funds, they possess all the powers and privileges of a corporation, they are quasi a corporate body. What is the judgment to be ? What the execution ? Can they be called on to enter special bail ? Can their bodies be surrendered ? Are they the subjects of the execution of the person ? On every suit is there to be an inquiry into the amount of their joint funds and judgment taken of that amount, a kind of judgment de honis or judgment quando aociderint ?

“Nor would I have any difficulty were the articles of association more explicit than they are and excluded from responsibility the associators other than out of their joint funds; for though they might, as between themselves, stipulate with each other for this contracted responsibility, yet as to the rést of the world it is clear that each partner is liable to the whole amount of the debt contracted.

“ Legal corporations are known — can be made responsible by their property and punished by the forfeiture of their charter. The mode of coming at their property is pointed out by law, but here we are without any guide. These self-created bodies corporate would be without any check or control did we lose sight of the individuals ; and there was no individual existence.”

In Witmer v. Schlatter, 2 Rawle 359, twelve years afterwards, Chief Justice Gibson said (p. 363), “ It is indeed supposed that he who deals with a company is bound to know the principles on which it is constituted, insomuch that he ipso facto agrees to contract according to the conditions of the articles. So differently is the law held in actions against joint stock companies, both here and in England, that the stipulations in the articles have never been allowed to exempt the members from liability beyond the joint funds or to restrain their responsibility to third persons on the general principles of partnership. It was indeed intimated by Justice Platt, in Skinner v. Dayton, 19 Johns. Rep. 513, and [484]*484by one of the judges of this court, in Hess v. Werts, 4 S. & R. 361, that partners may limit their liability by an explicit stipulation between them, and the party with whom they contract, but that such a limitation is never a matter of silent inference. But stipulations of this kind,’ says the learned commentator on American law, ‘ are looked upon unfavourably, as being contrary to the general policy of the law; and it would require a direct previous notice of the intended limitation to the party dealing with the company and his clear understanding of the terms of the limitation:’ 3 Kent’s Com. 5. Without such direct notice, therefore, the question of assent to the articles is not one of fact, but of law.”

In Ridgely v. Dobson, 3 W. & S. 118, twelve years later, Judge Huston, speaking of this case, says, “ In 2 Rawle 363 it is decided that if joint stock companies, not incorporated, contract debts they are answerable to pay them. On this point the court were unanimous, though a division on another ground.”

The courts possess extensive powers in granting charters of incorporation to persons associated for any literary, charitable, or religious purpose, which have been extended to many other associations, including mutual saving fund, loan, or building associations, and charters are granted under general laws to iron manufacturing, mining, and other companies; but all are under provisions securing a wholesome control over their actions and sometimes imposing personal liability in various forms, and punishing stockholders, members, officers, and directors for a dereliction of duty ; and the enrolment-tax on any law chartering a savings institution is one hundred dollars. Limited partnerships for the transaction of any agricultural, mercantile, mechanical, mining, and transporting of coal, or manufacturing business, may be formed by two or more persons upon the terms prescribed by law, but it does not authorize any such partnerships for the purpose of banking or making insurance.

It is clearly, therefore, against the general policy of the state to encourage or foster attempts on the part of individuals to secure to themselves a personal irresponsibility, which is appropriated to corporations created by or under special or general laws of the Commonwealth.

In the case of Hallett v. Dowdall, 18 Q. B. 2 (E. C. L. R. vol. 83), in the Exchequer Chamber, the limitation of responsibility of the shareholders of the assurance company was on the face of the policy, and there was an express agreement between the assurers and the assured that the capital stock and funds of the company should alone be liable to answer and make good all claims under the policy. Here therefore was an express and positive agreement to limit, and that is really the extent of the decision. Baron Martin says, “ It seems clearly established by [485]*485the authorities that, with respect to those persons who have no notice of the terms of the partnership, the stockholders and partners in joint stock companies are liable to the same extent and in the same manner as the partners in ordinary partnerships, and that the law pays no regard to the stipulations in the partnership deed as to the restriction of the liability, or to any particular provisions as to the mode of carrying on the business different from that ordinarily used in such concerns.

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

Related

Hershey Estates v. Rettew
19 Pa. D. & C. 262 (Philadelphia County Municipal Court, 1933)
National Shawmut Bank v. Hartford Accident & Indemnity Co.
12 Pa. D. & C. 119 (Philadelphia County Court of Common Pleas, 1929)

Cite This Page — Counsel Stack

Bluebook (online)
50 Pa. 479, 1865 Pa. LEXIS 191, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beavers-administrator-v-mcgrath-pa-1865.