Graveson v. Odd Fellows' Temple Co.

4 Ohio N.P. 112
CourtOhio Superior Court, Cincinnati
DecidedJuly 1, 1897
StatusPublished

This text of 4 Ohio N.P. 112 (Graveson v. Odd Fellows' Temple Co.) is published on Counsel Stack Legal Research, covering Ohio Superior Court, Cincinnati primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Graveson v. Odd Fellows' Temple Co., 4 Ohio N.P. 112 (Ohio Super. Ct. 1897).

Opinion

Smith, J.

The plaintiff entered into a contract with the defendant for the erection of a building known as The Odd Fellows Temple, the contract price for the same being over $100,000.

It was provided in the contract that the work was to be paid for from time to time as it progressed upon the estimate and certificate of the architect. Accordingly, from time to time such estimates and certificates were given to plaintiff, who presented them to the secretary, who gave him an order on the treasurer for the payment of the same.

It appears, however, that after the estimates and certificates of the architect were left with the secretary, he did not immediately draw his order on the treasurer, but waited for the approval of the Board of Directors, and that this interval of time varied, running from a few days in some cases to a much longer period in others. It also appears in most cases that after the secretary had drawn his order upen the treasurer, the treasurer was unable to pay them for lack of funds, and the plaintiff was delayed in the receipt of his money, sometimes for a few weeks, but more frequently for a longer period of time.

The plaintiff had frequent conversations with the treasurer in regard to interest which he claims was due him upon these estimates, claiming that he was entitled to interest on the same either from the time of the delivery of the estimate by the architect, or from the date of the presentation of the secretary’s order to the treasurer. The treasurer, while sympathizing with the plaintiff in his claim, contended that he had no-authority to pay interest, and that the matter would have to be determined by the Board of Directors. Notwithstanding the plaintiff’s claim that he was entitled to interest, he accepted from time to time payment of the amounts called for by the orders, and surrendered up the same to the treasurer.

The plaintiff brings this action to recover the interest which he claims should have been paid to him. The defense is that by acceptance of the principal of each order the plaintiff waived his right to interest.

. Interest is of two kinds — 1st: That which is given by reason of the contract providing for the same, and — 2nd: That which is given by way of damages. Thus in Perley on Interest, Page 5, it is stated that:

“Contractual interest is not given as damages, nor as the incident of the debt pro tanto. It is the debt itself, a substantive part of it as much so as the principal, for both were contracted for, and can be recovered as a, matter of right; while interest that is given as damages is simply incidental to the debt, and does not follow it as of right.”

In view of this distinction between the two kinds of interest, the-authorities seem to be uniform to the effect that where the interest is c mtractual,upon the acceptance by the creditor of the principal the right to recover the interest still remains; but where the interest is given by [113]*113way of damages, the acceptance of the principal is a waiver of the right to claim interest; and that subsequently no action can be maintained for the same.

This principle is stated in King v. Phillips, 95 N. C., 245, as follows:

“But when interest is stipulated for in the contract, it is as much a part of the debt as the principal itself. 1 Daniel on Neg. Ins. 919; 2 Edwards on Bills and Notes § 1012; Boodily v. Bellam, 2 Burr, 1096; Southern Central R. R. Co. v. The Town of Moravig, 61 Barb., 180; Fake v. Eddy, 15 Wend. 76, and Bledsoe v. Nixon, 169 N. C. 80; where the distinction is clearly stated. It was there held: “When there is no agreement to pay interest, interest when allowable is allowed not as a part of the contract, but as an incident and by way of damages for the default to make the creditor good for the loss he has sustained by reason of the breach of contract.” In this class of cases, it has always been held that after the principal of the debt has been paid and received in full, no action could be maintained to recover interest; the reason being, that interest in such cases being a mere incident, cannot exist without the debt, and the debt being extinguished, the interest must necessarily be extinguished also.

A distinction has been made between such cases and those where interest is payable by the terms of the contract. In the latter case, the interest is as much a part of the contract as the principal,and not amere incident; consequently there is no reason why in such case the interest may not be recovered even after the principal has been paid.” See also, Tillotson v. Preston, 3 Johnson 229; Dickson v. Parks, 1 Espinasse, 110; Jacks v. Emmett, 11 Paige 142; Ellsworth v. Fogg & Harvey, 35 Vt. 355.

It also appears from the authorities, in that class of cases in which the receipt of the principal is a waiver of the interest, that it is immaterial that protest is made at the time of its receipt. In the case of Cutter et al. v. The Mayor etc. of N. Y., 92 New York Reports, 170; in which the effect of a protest was considered, it ivas said:

The interest “is given as damages for non-payment or detention of the money awarded, and does not constitute a debt capable of a distinct claim. It could only be recovered with the principal by action. Acceptance therefore of the sum awarded in full payment of the principal prevents an action for those damages. If the plaintiff meant to have demanded the interest, she ought not to have received the principal. In the face of that fact, protest against the refusal of the defendant to pay interest is of no importance. (Fleetwood v. The City of New York, 2 Sandf. 481; Forrest v. The City of New York, (13 Abb. Pr., 350.)”

In view of the principles governing the acceptance of the principal without the interest., and m view of the fact that the contract between plaintiff and defendant made no provision for the payment of interest upon defaulted payments, the law would seem to be settled that the plaintiff in this case, by the acceptance of the principal of each installment, w'aived his rirght to subsequently claim any interest due upon the same, and that the fact that he was continually making claim for the interest did not prevent such waiver.

It is contended by the defendants, however, that all contracts in this state must be read as though the statutes relating to interest were imported into them; and that so read, the contract between these parties stipulated for interest, upon any defaulted payment.

[114]*114The sections of the statute relating to interest, are § 8179 to § 3183 (inc.). Section 3179 provides that parties may stipulate for the payment of interest at any rate not exceeding eight per cent. Section 3180 provides that all judgments upon contracts made as provided in § 3179, shall bear eight per cent interest.

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Related

Hamilton v. . Van Rensselaer
43 N.Y. 244 (New York Court of Appeals, 1871)
King v. . Phillips
95 N.C. 245 (Supreme Court of North Carolina, 1886)
Forrest v. Mayor of New York
13 Abb. Pr. 350 (New York Supreme Court, 1861)
Southern Central Railroad v. Town of Moravia
61 Barb. 180 (New York Supreme Court, 1871)
Jacot v. Emmett
11 Paige Ch. 142 (New York Court of Chancery, 1844)
Fake v. Addy's
15 Wend. 76 (Court for the Trial of Impeachments and Correction of Errors, 1835)
Ellsworth v. Fogg
35 Vt. 355 (Supreme Court of Vermont, 1862)
Fleetwood v. City of New York
2 Sandf. 475 (The Superior Court of New York City, 1849)

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Bluebook (online)
4 Ohio N.P. 112, Counsel Stack Legal Research, https://law.counselstack.com/opinion/graveson-v-odd-fellows-temple-co-ohsuperctcinci-1897.