Gilman v. Leavitt

1 Smith & H. 304
CourtSuperior Court of New Hampshire
DecidedNovember 15, 1813
StatusPublished

This text of 1 Smith & H. 304 (Gilman v. Leavitt) is published on Counsel Stack Legal Research, covering Superior Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gilman v. Leavitt, 1 Smith & H. 304 (N.H. Super. Ct. 1813).

Opinion

Smith, C. J.

The objection is that plaintiff, neither as one-third owner, nor master, can maintain this action for the freight; two of the defendants being owners of two-thirds of the rum, and two-thirds of the vessel in which it was brought.

It seems clear that plaintiff cannot recover the whole freight. This would be compelling the owners of two-thirds of the vessel to pay to the owner of one-third the whole freight. If entitled at all, it is only to one-third the freight, in respect of his share in the vessel; and to this he seems equitably entitled.

1. Objection. All the owners must join in an action for freight, even if we suppose Conner the sole owner of the rum, or that the three defendants were in no way connected with the plaintiff or the vessel.

The general rule is so. When a contract is made with several, all must join in the action. 1 Chitty, 5, 25, 26 ; Abbott on Shipping (98, 99). The non-joinder may be taken advantage of at the trial, and is ground of nonsuit. Indeed, it appears on this declaration. It is not pretended, in this case, on the part of the plaintiff, that the defendants made any express contract with him, in which case he might sue alone. 1 Chitty, 6, n. (z). The contract proved in this case is one which arises by implication of law.

But there are several exceptions to the general rule that all the parties to a joint contract must join.

One is, that, where two out of three have been paid or have received their shares, the third may, in respect of such severance, sue alone for his proportion. 1 Chitty, 7 ; Esp. 117; Garret v. Taylor, Abbott (98, 99). Now the present [306]*306case is in substance the same. G. Leavitt and J. T. 'Gilman owned two-thirds of the merchandise, — the rum; as owners of two-thirds of the vessel, their two-thirds comes freight free, which is the same thing as if A. and B. had been the owners of the rum with Conner, and had paid each of them their one-third of the freight of the rum. They are satisfied; they cannot sue ; the}' have no demand for the freight of the sixty-four puncheons of rum. Why should they join in the action for this freight, as they have nothing to receive? Stephen Gilman has something to receive. All that is due is his. This necessarily works a severance, and takes the case out of the general rule.

This exception, as it respects torts, was recognized and established- in Addison v. Overend, 6 T. R. 766; and Sedgworth v. Overend, 7 T. R. 279. There, one of two joint owners of the vessel had been paid his share of the damage done to the vessel; and it was held he could not, and consequently need not, join in the action to recover the residue of the daqiages sustained. That action was properly brought in the name of the party entitled to whatever might be recovered.

In Baker v. Jewell, 6 Mass. 460, Parsons, C. J., applies this doctrine to actions founded on contract. Where one is answerable to two or more, jointly, and he adjusts the matter with either of them, so that he has no longer an interest in the dispute, this is a severance of the cause of action,

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Related

Austin v. Walsh
2 Mass. 401 (Massachusetts Supreme Judicial Court, 1807)
Lane v. Penniman
4 Mass. 91 (Massachusetts Supreme Judicial Court, 1808)
Baker v. Jewell
6 Mass. 460 (Massachusetts Supreme Judicial Court, 1810)

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Bluebook (online)
1 Smith & H. 304, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gilman-v-leavitt-nhsuperct-1813.