Hallam v. Maxwell

2 Cin. Sup. Ct. Rep. 136
CourtOhio Superior Court, Cincinnati
DecidedJanuary 15, 1872
StatusPublished

This text of 2 Cin. Sup. Ct. Rep. 136 (Hallam v. Maxwell) 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
Hallam v. Maxwell, 2 Cin. Sup. Ct. Rep. 136 (Ohio Super. Ct. 1872).

Opinion

Walker, J.

Sait is brought, in this ease, to recover for legal services rendered in representing the. trustees of the estate of L. C. Hopkins in bankruptcy, in a certain ease in the Kentucky courts. It is admitted that the defendants had no interest whatever in the matter, except as such trustees, and that the plaintiffs knew that they appeared in the suits only in that capacity, and it appears that when they presented their bill they made it out in the name of the trustees. This suit is, however, brought against Maxwell & Jordan personally, for the services which were rendered in representing the trustees.

There are three defenses set up in the answer:

1. That the employment was to represent the trustees, and that the parties therefore were not liable personally.

[137]*1372. That no notice of the suit had been given to the defendants, in accordance with section 14 of the bankrupt act, under which they were acting.

3. A denial that the services were worth what is charged.

There is no evidence to show that these defendants are liable personally in this case, unless on the broad ground that a trustee in bankruptcy necessarily incurs a personal responsibility in reference to everything that he does in the performance of his trust, no matter how necessary it may be, or whether the estate has funds or not. There is no evidence in the case to show that the trustees have not funds in their hands, nor that the services were not necessary t'o secure the trust property; on the contrary, the evidence is that they were.

I have been able to find no case in the books holding this broad ground. The cases referred to by counsel for plaintiff do not reach it. '

The case of Raw v. Cutten, 9 Bing. 102, also reported in 2 Moore & S. 123, simply holds that an assignee in bankruptcy will not be liable for the loss of money belonging to the trust, through the default of an agent employed by him, unless he has been guilty of negligence in the selection of the agent. On the contrary, the language of the opinion would seem to me to look the other way.

Tindall, C. J., in delivering the opinion of the court, says:

“ And, again, in Ex parte Belchier, Amb. 218, Lord Hardwicke goes much more fully into the principle, by which the question of the assignee’s liability is to be governed. That was a case where the assignee, after employing a broker to sell tobacco, the property of the bankrupt, allowed the money to remain in his hands ten days, when he died insolvent. Lord Hardwicke said: If the assignee is chargeable in that case, no man of sense would act as assignee under a commission of bankruptcy. This court has laid down a rule with regard to the transactions of assignees, and more so of trustees, so as not to strike a terror into mankind acting for the benefit of others, and not for their [138]*138own. Courts of law and equity, too, are more strict as to executors and administrators; but where trustees act by other hands, either from necessity or conformably to the common usage of mankind, they are not answerable for losses.’ In another part of the judgment he adds: ‘ The assignee in this case acted as prudently for the trust as for himself, and according to the usage of business.’”

And Chief Justice Tindall proceeds, page 103: “Inasmuch, therefore, as the provisional assignee had the power, both from the necessity of the case, and also from the ordinary course of business observed on similar occasions, to execute this part of his duty by means of a¡n agent, and as there is the entire absence of fraud on the part of the defendant, and no proof of negligence in choosing an insufficient or dishonest person as his agent, we hold, upon the authority of the cases above referred to, that he is not to be charged with the money received by Williams, and not paid over to the defendant, in an action for money had and received by him to the use of the plaintiff.”

The other case referred to by counsel was March v. Clarke, 10 Bing. 102. In this case the assignee had received money due the estate under a void' assignment, and was sued by the bankrupt to recover it. The court held that he would be liable if it was still in his hands, but if he had paid it into bank, as required by the law, he would not be.

These were the only cases to which I .was referred by counsel, and they seem to me to be far from supporting their position.

An analogy was suggested by counsel, as well as in the case of Raw v. Cutten, cited above, between the liability of an assignee and that of executors or administrators, but I have not been able to find a single case imposing so extensive a liability upon executors or administrators.

The strongest authority I ‘can find is- a passage in Tiffany and Bullard on Trustees, 583:

“Purchases made by trustees, executors, administrators, or guardians, when made in obedience to the duties of the [139]*139trust, impose, upon them personal liability, and the seller must look to them, and they to the trust estate, for reimbursement.”

The cases cited to sustain this proposition are but three in number, and do not seem to sustain the position. They are all cases of executors, except Sanford v. Howard, 29 Ala. 101, which was the ease of a guardian. In this case, the order was as follows : “Let the children of Jacob May-berry, deceased, have any goods they wish, and charge them to the children separately, and I loill fay for them at the end of the year, or as soon as the cotton crop is sol'd.” This was, as the court say, a clear personal undertaking, and'afforded full ground for holding the guardian to a personal liability.

Harding v. Evans, 3 Port. (Ala.) 221, is a case where the statute required the executor to carry on the farm during the residue of the year in which the intestate died. The suit is for goods purchased, but the court say that it does not appear that the goods were purchased for the support of the plantation during that year.

The ease was therefore not made out. It is true, the court go on to say: “But if it did so appear, neither the statute referred to, nor any other principle of law, would relieve the administrator from liability for the articles purchased by him. The statute gives a sufficient indemnity to the administrator in cases of this kind (and which is, perhaps, only the same that he could have claimed under the common law), that all expenses in continuing the plantation may be deducted from the amount of assets which may come into the hands of the administrator.”

So in Lovell v. Field, 5 Vt. 218, where an administrator bought goods for the benefit of the estate, he was held personally liable, but there was nothing to show that.it was his duty to buy them. It is singular that no authorities are cited in either of these cases.

These cases, then, when strictly analyzed, do not sustain the doctrine that a trustee is liable personally, when acting [140]*140strictly within the line of his duty, and in good faith for the benefit of the trust estate.

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Related

Lovell v. Field
5 Vt. 218 (Supreme Court of Vermont, 1833)

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Bluebook (online)
2 Cin. Sup. Ct. Rep. 136, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hallam-v-maxwell-ohsuperctcinci-1872.