Ex parte Wyant

8 Ohio N.P. (n.s.) 207
CourtHamilton County Court of Insolvency
DecidedMarch 15, 1909
StatusPublished

This text of 8 Ohio N.P. (n.s.) 207 (Ex parte Wyant) is published on Counsel Stack Legal Research, covering Hamilton County Court of Insolvency primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ex parte Wyant, 8 Ohio N.P. (n.s.) 207 (Ohio Super. Ct. 1909).

Opinions

Warner, J.

Tbe petitioner was committed by James S. Myers, a justice of tbe peace, to tbe custody of tbe sheriff of Hamilton county, and, in default of bail, was lodged in 'jail upon a charge preferred by his wife, Irene Wyant, “for unlawfully neglecting and refusing to provide with a necessary and proper home, care, food and clothing, one ITazel Wyant, a minor child under the age of sixteen years, he the said Kenneth Wyant, alias Clay Yan .Kerner, being then and there the father of said minor child,'’ [208]*208Thl petitioner now seeks to be discharged from’ custody under this writ. He alleges that he is “illegally restrained and deprived of his liberty without any legal authority by” said sheriff. The return of the sheriff certifies' that the petitioner was taken into custody and is detained “by virtue of a mittimus issued by “said justice of the peace,” and “a true copy” thereof is exhibited showing the charge aforesaid, the default of bail, •and the usual command to receive the petitioner into custody, to remain there until ‘ ‘ discharged by due course of law. ’ ’ The mittimus on its face appears to be regular and legal in form.

This prosecution was commenced under the provisions of an act of the Legislature entitled “an act to compel parents to maintain their children,” passed and approved April 28th, 1908 (99 O. L., 228). The petitioner claims in support of the allegations-of his petition herein, that at the time said act was passed an'd approved, and for a long time prior thereto, and at all times since, he''was a non-resident of this state and not amenable to its laws or subject to the jurisdiction of its courts, in the matters charged against him, .and offered himself as a witness to give evidence of such non-residence. Tim prosecuting attorney on behalf of 'the sheriff .objected to such, or any testimony, and contended''that in habeas corpus the petitioner must stand or fall upon the record in the case, and that any evidence cle hors that record was entirely immaterial and incompetent. The petitioner was permitted to testify and the court reserved its decision as to the right to so testify and the competency of such testimony for further consideration.

Section 5729, Revised Statutes, provides:

“If it appear that the person alleged to be restrained of his liberty is in custody of an officer under process issued by a court or magistrate * * * and that the court or magistrate had jurisdiction to issue the process * * * or make the order, the writ shall not be allowed. ’ ’

The provisions of this section limit the inquiry in habeas corpus' cases like the one at bar to the question of jurisdiction. Jurisdiction has been defined to.be “power to hear and determine” a cause,- and such authority must extend both to the [209]*209subject-matter and the-person. As sometimes stated there must be jurisdiction of the “person, place and subject-matter” (Church on Habeas Corpus, Section 368), and if either is wanting the imprisonment is without “authority of law” and void. Clearly if the law under which a party is committed is unconstitutional, the entire proceeding is a nullity, and a prisoner may be discharged on habeas corpus. Under the provisions of Section 5729, stipra, jurisdiction in the magistrate “to issue the process or make the order” must necessarily exist, and want of jurisdiction of either the subject-matter, or -the person, would fairly seem ,to make any action a nullity.

When the want of jurisdiction appears on the face of the record the petitioner must of course be discharged; but may the petitioner show by evidence aliunde the record that the magistrate was without jurisdiction to commit? The general rule, established by Federal authority, and prevailing in the courts of the states, is that “jurisdiction is always an open question, and may be inquired into by any court or judge competent to issue .the writ” (Church on Habeas Corpus, Sections 233 and 236). If an “open question” then any essential element of jurisdiction must be subject to investigation; and when the proceedings show, on their face, necessary jurisdictional facts, as is usually the case, it would seem to be proper to controvert such showing by evidence to establish the falsity thereof, for surely a prisoner should not be detained in custody on proceedings that are based upon false premises as to essential jurisdictional matters.

In this state it was held in Re Wm. J. George et al, 5 C. C., 207, that “in a proceeding in habeas corpus evidence may be given to prove the want of jurisdiction in the court to make the order” complained of. It is contended, however, on behalf of the sheriff that the George ease is practically overruled by the Supreme Court in Burns v. Tarbox, 76 O. S., 520. It appears in the George ease that a suit had been brought in the Probate Court of Putnam county by Richard Gilmore against the Findlay, Ft. Wayne & Western R. R. Co., under Section 6448, Revised Statutes, to recover compensation for land unlawfully taken without payment by said company. After judgment against [210]*210the company and execution returned unsatisfied, an injunction was issued by said probate court restraining the company from using and occupying the premises. George and others, employes of the defendant company, violated the order of injunction, and were fined for contempt of court, and committed to jail until such fines and costs should be paid, whereupon a writ of habeas corpus was sued out in the proper circuit. On the hearing evidence was admitted de hors the record to show want of jurisdiction in the probate court to issue the restraining order. It will be observed that here was a final order committing the 'petitioners to jail, from which they sought relief by habeas corpus.

In Burns v. Tarbox a warrant had been issued by the mayor of Xenia, for the arrest on a charge "of non-support of his children, of Burns who claimed to reside in. Cincinnati. He was arrested in Cincinnati and sued out a writ of habeas corpus in the common pleas court. On the hearing Burns offered evidence to show various defenses to the prosecution in Greene county, one of 'which was that he was a resident of Hamilton county. The court refused to hear or consider the evidence and remanded him to the custody of the sheriff of Greene county, and when the habeas corpus case reached the Supreme Court it was there

“Held: The evidence offered was not competent to worK the discharge of B. on habeas corpus, the same being competent and appropriate as a part of his defenses to the charge before said mayor.”

In the opinion of the court, Price, J., says:

‘ ‘ The evidence offered and excluded would be perfectly competent on the trial of the accused before the mayor who issued the warrant, and if the facts tendered should be established, he would be entitled to an aequital of the charge as was had in State v. Dangler.”

In the Dangler case, 74 O. S., 49, the Supreme Court had held that “a prosecution * * * for non-support * * * must be instituted in the county in which the defendant resides at the time he neglects or refuses to furnish the support.” It is apparent that the holding of the Supreme Court was based upon [211]*211the jurisdictional regularity, on its face, of the proceeding before the mayor, and the further fact that such proceeding was pending,

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Cite This Page — Counsel Stack

Bluebook (online)
8 Ohio N.P. (n.s.) 207, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ex-parte-wyant-ohctinsolvhamil-1909.