Citizens Savings & Trust Co. v. Gibson-Spence Coal Co.

16 Ohio N.P. (n.s.) 273

This text of 16 Ohio N.P. (n.s.) 273 (Citizens Savings & Trust Co. v. Gibson-Spence Coal Co.) 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
Citizens Savings & Trust Co. v. Gibson-Spence Coal Co., 16 Ohio N.P. (n.s.) 273 (Ohio Super. Ct. 1914).

Opinion

Kineead, J.,

. This ease has been tried twice. The action is to recover $1,-177.96 on two promissory notes. The defense was that the plaintiff took the notes with knowledge that they were given as advance payments for coal to be delivered in the future, the facts showing that the payee was unable to deliver the coal. ..In-the [274]*274first trial a non-suit was ordered because it was not shown that the plaintiff was not a Iona fide holder of the note sued upon. •

A new trial was granted because the court entertained a suspicion from the evidence that all facts and circumstances had not been disclosed in respect to the question whether the bank had notice of the equities. The new trial ivas granted also out of an abundance of precaution on the ground that it might properly be a question for the jury to draw an inference from the circumstances the fact of such knowledge.

On second trial the evidence developed the facts .and circumstances much more fully, shedding all the possible light upon the question whether the bank was chargeable with knowledge of the claims of defendants. The verdict of the jury was that it was not, the finding being for the plaintiff.

On motion for new trial it strongly urged that error was committed in not charging the jury that it could render a verdict by a three-fourths vote. It is also claimed that the court erred in its charge to the jury.

The action was commenced July. 8, 1913.

The first cause of action accrued and was existing April 10, 1913. The second cause of action accrued and was existing March 26, 1913.

It is urged that the case of Elder v. Shoffstall, decided by the Supreme Court. June 16, 1914, Ohio Law Reporter, June 29,

1914, requires a reversal of the. action of the court because the jury was required to render a unanimous verdict.

The course pursued in this case is the one followed by this court in all its branches upon mature reflection and consideration. It is the rule followed generally by the trial courts. The trial courts had long had the benefit of the case above cited as reported by the court of appeals in Shoffstall v. Elder, 17 C.C. (N.S.), 182. The Supreme Court affirmed the decision, reaching the same conclusion that the amendment to the jury law which became effective May 14, 1914, did not affect actions pending prior to that date. That action was commenced March 21, 1913. It went to trial May 6, ,1913, the court charging,the jury May 20, 1913. The court applied the amended jury law,' the verdict [275]*275being rendered by'only ten jurors. This action was reversed by the court of appeals because the amended act did not affect pending actions. It followed a rule of the Supreme Court that in construing an amended or repealing act it must be read as though Section 26 was in fact part of the section construed. This rule the Supreme Court reiterates in the opinion in Elder v. Shoffstall, supra (opinion not'published). It was held that there was no express language contained in the amendment which clearly indicáted a legislative intent to make the amendment applicable to pending eases, the words “in all civil actions” not being sufficient.

It is not urged that the opinion of the Supreme Court in this case as expressed in the syllabus requires a reversal of the verdict in this ease. The language of the 2d syllabus would by its letter seem to sustain such contention. It is as follows:

‘ ‘ This amended section relates to the remedy only arid applies to all actions commenced in the common pleas courts of this state on and after the 14th day of May, 1913, regardless of the time when the cause of action arose. ’ ’

It is respectfully submitted that the second proposition of the above syllabus was beside the actual question involved in that case, which was whether the amendment should apply to a ease pending, the trial of which was commenced before the act took effect and which was submitted to the jury after the same went into effect.

To say in that case that the amendment applies to all actions commenced, after May 14, 1913, regardless of the time when the cause of action arose, is to undertake to make a rule in a case not before the court, and ignores the latter part of Section 26. It is familiar doctrine that amendatory enactments in some instances may properly be applied to certain remedial rights without infringement thereof. This is because there is no vested right in such remedy.

But the right to a jury trial by .unanimous verdict was a common law, constitutional right, of which neither party could" be deprived without both constitutional and statutory amend[276]*276ment. The opinion of the Supreme Court in the- case cited: holds it to be a constitutional right, taking jurisdiction of the case because it involved a constitutional right. The final act in changing this fundamental right did not occur until May 14, 1913.

•The constitutional amendment authorizing the amendment was'not self executing, but required' legislation to make it effective, so that it did not become operative until the date, named.

To state that the amendment relates to the remedy, and therefore to hold that a verdict shall be rendered in accordance with • its. provisions in an action commenced after May 14, 191-3, regardless of when the cause of action arose, seems with due respect, to be a misconception. At the moment -when default occurred on the notes in question, March 26, 193 3, a remedial right came into existence in the plaintiff, to commence an action in court. The right thus arising was.as much a part of the 'remedy, as was the right to submit it to a jury at trial. The right thus ■ springing into existence updn default of defendant-was not. only: a constitutional remedial right at such time, but it was carefully and explicitly guarded and preserved by existing statutory provision, viz.': ' ' ‘ '

“Section- 26. Whenever a statute is. * * -amended^,, such * * * amendment shall, in no manner affect pending^ actions, * * *' civil * * * and when' the amendment relates to the remedy, it shall not affect pending actions, * unless so expressed, ’* * ■*' nor shall' any' * * * amendment affect causes of action, * * * existing at the• time, of such amendment * * * unless otherwise expressly provided in the amending * * * act.” ' .

The Supreme Court states that the amendment relates to, 'but does not actually hold that it applies the remedy regardless of the time when the cause of action arose, because the time when' the cause arose was not involved in the case, supra. The unpublished opinion of the Supreme Cburt in Elder v. Shoff stall Has been examined, wherein it is found that the same statement appears as is found in the published syllabus, prop. 2. In all[277]*277’ other respects the opinions therein contained and herein expressed are consistent. It is clear that the decision of the Supreme Court is not an authority on the question involved in this case, except as the opinions therein found on the questions incidental and leading up to the final one involved are in harmony. Section 26 so plainly provides that the amendment to the jury law shall not affect causes of action existing at the time of such amendment

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Bluebook (online)
16 Ohio N.P. (n.s.) 273, Counsel Stack Legal Research, https://law.counselstack.com/opinion/citizens-savings-trust-co-v-gibson-spence-coal-co-ohctcomplfrankl-1914.