Eldridge & Higgins v. Heaton & Co.

7 Ohio C.C. 499
CourtOhio Circuit Courts
DecidedSeptember 15, 1893
StatusPublished

This text of 7 Ohio C.C. 499 (Eldridge & Higgins v. Heaton & Co.) is published on Counsel Stack Legal Research, covering Ohio Circuit Courts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eldridge & Higgins v. Heaton & Co., 7 Ohio C.C. 499 (Ohio Super. Ct. 1893).

Opinion

Stewart, C. J.

The plaintiff in error claimed damages for a breach of an oral contract made and to be performed in Pennsylvania, but not to be performed within the space of one year. This contract is within the statute of frauds of Ohio, and if made here, no action would lie for its breach. The court below held in effect that although this contract was made and was valid in Pennsylvania, the evidence by which it was sought to establish this contract was incompetent under our statute of frauds, not attempting to annul or declare void the contract, but saying that the courts of Ohio will not allow the parties .to prove such contract; that they must enforce it in the state where it is made, or in states where such contracts are valid.

Direct authority for the decision of the court below is found in the case of Leroux v. Brown, 12 C. B. 801. In that case, after full argument, it was decided that a suit could not be maintained in England upon a contract made in France, valid by the laws of France, but falling within the inhibition of the fourth section of the English statute of frauds. That case fully recognized the well known rules of law that the nature, validity, interpretation and effect of a contract are determined by the laws of the state or country where it is made, but applying the equally [502]*502well established rules of law that the lex fori regulates the form of the action and the nature and extent of the remedy, construed the fourth section of their statute of frauds as a statute applying to the remedy only, and not to the foundation of the contract. The language of the fourth section of the English statute of frauds at the time of the decision of Leroux v. Brown, supra, was substantially the same as our section 4199, Revised Statutes : “No action shall be brought whereby to charge,” etc., and the decision rests upon the construction which the court put upon this language, as distinguished from the language of the seventeenth section, that no contracts shall be allowed to be good,” etc.; the former section being held applicable to the remedy only, and the latter going to the substance of (he contract. That when the law says : “ No action shall be brought,” it means that a party shall have no remedy upon such a contract; that the courts will not issue process or otherwise assist in the enforcement of it. That case has never been overruled in England, and although criticised by some judges, it has been regarded as authoritative, and followed whenever the facts in a case warranted it. Many text writers on the conflict of laws and statute of frauds lay down the law as announced in Leroux v. Brown, but the foundation for the text is always Leroux v. Brown, and other cases which have followed that case, either arbitrarily without reasoning, as Downer v. Cheeseborough, 36 Conn. 39, or accepted it because the language of their statute of frauds was the same as the fourth section of the English statute, as Kleeman v. Collins, 9 Bush. 470. Referring to the reasoning which is at the foundation of Leroux v. Brown. Willes, J., in Williams v. Wheeler, 8 C. B. N. S. 316, says: I am not satisfied that either of the sections of the statute of frauds to which reference was made, warrants the decision.” And Browne in his work of the Statute of Frauds (section 115), says that the attempt to draw a distinction between sections 4 and 17 of the statute of frauds is not warranted for the reason that the whole statute is evidential only, and [503]*503while citing Leroux v. Brown, rejects the reasoning upon which it is founded. In the numerous cases cited by counsel for plaintiffs in error,,we have only been able to find one (Cochran v. Ward, 29 N. E. 795), which in passing upon a statute in language similar to the fourth section of the English statute of frauds repudiates Leroux v. Brown, although the cases are numerous where the court intimates that if necessary Leroux v. Broion would be repudiated. On the other side, many cases are cited in which the language used in Leroux v. Brown, is cited apparently with approval, but only by way of illustration, and not as decisive of or affecting the case before the court. So at last, it seems to us, that if we regard the reasoning in Leroux v. Brown, based as it is on the language of the statute of frauds, or the claim of Browne in his work on the Statute of Frauds that it relates solely to the question of the evidence Uy whic£i a contract may be proven as sound, the judgment of the court below must be affirmed, and otherwise it cannot be. It is conceded at the outset that:

1. Lex loei determines as to tne nature, validity, interpretation and effects of a contract.

Which in fewer words is expressed by saying that a contract valid where made is valid everywhere.

Upon this subject Judge Stony writing before the case of Leroux v. Brown was decided, says (Conflict of Laws, sec. 261):

Every person contracting in a country is understood to submit himself to the law of the place, and silently to assent to its action upon his contract. The law of the place of the contract acts upon it independently of any volition of the parties, in virtue of the general sovereignty possessed by every nation to regulate all persons, property and transactions within its own territory. And in admitting the law of a foreign country to govern in regard to contracts made there, every nation recognizes, from a principle of comity, the same right to exist in other nations, which it demands and exercises for itself.”

[504]*5042. The lex fori regulates the form of the action and the nature and extent of the remedy. That is, it determines (a) the parties who may sue and be sued#; (b) the time within which suit may be brought; (e) the form of action, and id) the nature, effect and extent of the remedy applied.

This, we think, is the extent to which the lex fori governs in suits upon contracts made in other states or countries, and to carry it beyond that is a violation of a well settled rule in the law of contracts; and the decisions which hold that the legislature may change at will the laws regarding the competency and credibility of witnesses do not vary this rule.

But where the objection is not to the competency, but the effect of evidence the lex loci should prevail. Thus a parol acceptance can only be proved by parol evidence, and therefore, if valid where made, it would be unreasonable to reject it because by the lex fori an acceptance must be in writing. Í Dan’l Neg. Ins. § 888. Mason v. Dousay, 35 Ill. 424.

By the American and English law contracts svhich fall within the purview of what is called the statute of frauds are required to be in writing. If such contracts made by by parol, per verba, in a country by whose laws they are required to be in writing, are sought to be enforced in any other country, they will be held void, exactly as they are held void in the place where they are made. And the like rule applies vice versa, where parol contracts-are good by the law of the place, where they are made; but they would be void if originally made ijn the place where they are sought to be enforced for want of certain solemnities, or for want of writing as required by the local law.”

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

Related

Von Hoffman v. City of Quincy
71 U.S. 535 (Supreme Court, 1867)
Downer v. Chesebrough
36 Conn. 39 (Supreme Court of Connecticut, 1869)
Mason v. Dousay
35 Ill. 424 (Illinois Supreme Court, 1864)
Cochran v. Ward
29 N.E. 795 (Indiana Court of Appeals, 1892)

Cite This Page — Counsel Stack

Bluebook (online)
7 Ohio C.C. 499, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eldridge-higgins-v-heaton-co-ohiocirct-1893.