Hayes v. Jones

2 Patton & Heath 583
CourtCourt of Appeals of Virginia
DecidedJanuary 15, 1857
StatusPublished

This text of 2 Patton & Heath 583 (Hayes v. Jones) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hayes v. Jones, 2 Patton & Heath 583 (Va. Ct. App. 1857).

Opinions

FIELD, P.

This case upon the trial, referred to in the first bill of exceptions, seems to have been somewhat different from the facts proved on the final trial. The first was the case of a verbal promise made by the father to make a gift of slaves to the daughter and her husband in consideration of the marriage, and the delivery of the slaves to the husband, by the father, in execution of the promise after the marriage had taken place. On the' last trial, it appeared to be a verbal gift of slaves from the father to the daughter, not accompanied by the transfer of the possession thereof at the time from the father to the daughter, but the possession of which was retained by the father until after the marriage took place, and then after the lapse of two days or more delivered to the husband by the father. But from the view I have taken of the case, it is not material to ascertain whether it is to be regarded as the case of a verbal promise of a gift of slaves in consideration of the contemplated marriage, and the delivery of the property to the husband in fulfillment of the promise after the marriage had taken place; or whether it is to be regarded *'as a verbal gift of slaves made by the father to the daughter before the marriage, but the possession of which remained with the father until two days or more after the marriage had taken place, and then delivered to the husband by the father. In either aspect of the case, I regard the law to be the same, so far as the rights of the creditors of the father are concerned. It appears from the record that the father was totally insolvent at the time of making the promise or gift, and unable to pay his debts. Nevertheless, if he had, before the marriage took place, made a perfect gift of property in consideration of the marriage, or obligated himself, by a written promise, to make the gift after marriage in consideration of the marriage, and had actually made the gift pursuant to the promise, the husband’s title to the property, notwithstanding the insolvent condition of the father, would have prevailed against the claims of the creditors, because marriage is regarded as a valuable consideration. See the case of Huston’s adm’r v. Cantrill et als., 11 Leigh, 136. If the promise or agreement, made before marriage, be in writing, the performance of it can be enforced by the husband after the marriage. But if the promise or agreement be made before marriage, and be verbal only, and the gift or settlement be not made until after the marriage takes place, whether that gift or settlement is [852]*852valid against the claims of creditors appears not to be a settled question. We find in the books many decisions pro and con of high authority: a few only of which I purpose to notice.

The strongest case to be found to support the validity of a post-nuptial settlement made pursuant to a verbal promise made before marriage, wa.s decided by Lord Chancellor Thurlow. This is the case of Dundas v. Dutens, 1 Ves. jun. 196, but better reported by Mr. Cox, who was counsel in the cause, in 2 Cox, 235. This case appears to have been recognized and followed by the Court of King’s Bench in Shaw v. Jakeman, 4 *East, 207; but was questioned by Sir William Grant, Master of the Rolls, in Randall v. Morgan, 12 Ves. jun. 67-74, and is contrary to principles laid down in Spurgeon v. Collier, 1 Eden. 61. It accords with the cases which arose prior to the passage of the statute of frauds, 29 Charles II—such as Griffan v. Stanhope, Cro. J. 454, and Sir Ralph Bovy’s Case, 1 Vent. 193. But Dundas v. Dutens can derive no support from decisions made prior to the statute of frauds, because until the passage of the statute of 29 Charles II, it was not requisite that such provisions should be in writing. Nor can the case of Dundas v. Dutens derive any support from cases in which the decision did not turn on the mere parol promise, but on considerations of fraud, and in which the verbal promise made before marriage to make a settlement was enforced in order to relieve against the fraud. Of this class is the case of Montacute v. Maxwell, 1 P. Wms. 620, in which the Lord Chancellor said, “In cases of fraud equity should relieve, even against the words of the statute,” &c. It this case the husband had practiced a fraud on the credulity and confidence of his wife, and thereby induced her to marry him, although he had not executed according to promise the marriage settlement. The chancellor compelled him to make the settlement according to the ante-nuptial verbal promise.

In the argument of this case the appellant’s counsel relied very much on the case of Argenbright v. Campbell et ux, 3 H. & M. 144. That case was substantially as follows.: John Campbell, upwards of eighty years of age, made a will by which he gave the land on which he resided to his daughter Rebecca, subject to his own life-estate therein and to the payment of ^50 to his daughter Hannah. He wished Andrew Campbell to marry his daughter Rebecca, and told him that if he married her," and complied with the will, he should have the land. Andrew Campbell did marry Rebecca. After which, John Campbell executed his obligation in writing to Andrew Campbell, in which, after citing the verbal ^promise, the making of the will and the marriage of Andrew Campbell with his daughter Rebecca, he bound himself not to alter or change the will so far as it related to the land, and not to convey the land so as to deprive Andrew Campbell and his heirs or assigns of the benefit thereof. After the execution of this bond John Campbell offered the land for sale, and Argenbright, being in treaty for the purchase, was notified by Andrew Campbell of his claim to it, who also inserted in the Staunton paper a notice cautioning persons against purchasing the land, and had the bond recorded in the district court at Staunton in April, 1794. Ar-genbright nevertheless, in disregard of the notice, went on to make the purchase and had his deed executed the 3d day of May, 1794. The suit was brought by John Campbell. and wife to have the deed set aside and the land convej-ed to them. John Campbell having died pendente lite, the decree of the court required Argenbright to convey the land to Rebecca Campbell and to account for rents and profits since the death of John Campbell, and required Andrew Campbell to pay the ^50 to Hannah Campbell. The bare statement of this case should be sufficient to shew that between it and the case at bar there is no analogy in their material points. Eor suppose it be admitted that if John Campbell had been an insolvent man, and that the claims of his creditors would prevail over the claim of Andrew Campbell and wife, under the will and bond, yet as John Campbell was not in debt, and as Argenbright had become a purchaser with full notice of the claim of Andrew Campbell and wife, he was himself guilty of fraud in purchasing the land after full notice, and should be compelled to surrender the title, thus fraudulently acquired, to Mrs. Campbell, and this is the very thing which the court compelled him to do.

The cases chiefly relied on by the appel-lee’s counsel, to show the invalidity of a post-nuptial settlement upon a verbal promise made before marriage, are the cases of Spurgeon v. Collier, before referred to, and Reade v. *Livingston, 3 John. C. R. 489. The case of Reade v. Livingston was decided by Chancellor Kent, who held that “a settlement after marriage, in pursuance of a parol agreement entered into before marriage, is not valid.” Tlie rule laid down by Chancellor-Kent has been followed by the Supreme Court of South Carolina, in the case of Izard v. Izard, 1 Bailey’s Eq. Rep. 228, and by the North Carolina court, in Koonce v. Bryan, 1 Dev. & Bat. Equity R. 227.

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2 Patton & Heath 583, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hayes-v-jones-vactapp-1857.