Heidelbach, Seasongood & Co. v. Slader

1 Handy 456
CourtOhio Superior Court, Cincinnati
DecidedJanuary 15, 1855
StatusPublished

This text of 1 Handy 456 (Heidelbach, Seasongood & Co. v. Slader) 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
Heidelbach, Seasongood & Co. v. Slader, 1 Handy 456 (Ohio Super. Ct. 1855).

Opinion

Gholson, J.

It will be proper, first to enquire as to the form of rem-edy the plaintiffs have adopted; whether upon the facts in the case an action for use and occupation will lie? On this point there is a decision of the Supreme Court of Ohio, Peter vs. Elkins, 14 Ohio 344, in a case very similar to the present. In that case, it is said, that the action of assumpsit for use and occupation, will not lie at the suit of a purchaser of mortgaged premises, sold under a decree in chancery, against a tenant in possession, under the mortgagor.

In the case of Peter vs. Elkins, as in this,, the title accrued to the plaintiff before the termination of the lease from the mortgagor to the defendant, and of his occupancy under it, but the Court held there was no right to recover for any portion of the time. The principle, on which the decision was made, was that “the action for use and occupation will lie only between persons holding the relation of landlord and tenant.” 14 Ohio 345, citing 6 Ohio 371; 4 Id. 205. “It springs from, the mutual assent of owner and occupant, that the latter holds by permission of the former.” “ The assent to establish a ten[459]*459ancy may be implied from acts.” 14 Ohio 346. It will be “ implied from the actual occupation and enjoyment of the premises, by the permission of the owner, or other person having the power of disposal, when such use and occupation had been beneficial.” 4 Metc. 224, 228; 12 M. & W. 323. (n.)

In has been supposed that an action for the use and occupation of land was introduced by Stat. 11 Geo. 2 C. 19, § 14; 1 Denio 38; but this appears to be a mistake; the operation of that Statute being only to prevent proof of a demise, unless by deed, from being fatal to the action ; and, thus, though that Statute regulated, or better established, it did not introduce the action. Gibson vs. Kirk, 1 Q. B. 850, 855; 41 E. C. L. 809; Beverly vs. Lincoln, 6 A & E. 829, 33 E. C. L. 226, (note.) An action for use and occupation being maintainable at common law, from the nature of the action, this principle is said to result, "that he who holds my premises without an express bargain, agrees to pay what a jury may find the occupation to be worth.” Mayor of Thetford vs. Tyler, 8 Q. B., 55 E. C. L. 95-100.

It is said on this point, in the case of Gibson vs. Kirk: " The truth is, that the occupation of land by a person bound to pay some remuneration for it, without the amount or time of payment being fixed, was, and is now, of rare occurrence. When it does occur, the implied contract is raised by law from the fact, that land belonging to the plaintiff has been occupied by the defendant by the plaintiff’s permission; the obligation is co-extensive with, and measured by the enjoyment; as soon as the occupation ceases, the implied contract ceases; and as no express time is limited, the remuneration must necessarily [460]*460accrue from day to day.” The substantial matter is, that the defendant occupies, by the permission of the owner entitled to receive remuneration for the use of his land. Where that permission is given to the defendant in any form, and followed by an occupation of the premises on his part, without objection to the title claimed, or the setting up an adverse title, a contract to pay may be fairly implied. If, on the contrary, “the circumstances of the case are inconsistent with the existence of a contract, and, necessarily, upon any fair construction, rebut every implication of a promise to pay rent, this form of action will not lie.” Croswell vs. Crane, 7 Barb. 191, 203.

In view of these principles, I have come to the conclusion, from what passed between the plaintiffs and the defendants, that if the plaintiffs were really the owners of the premises, so as to be entitled to remuneration for their use, a contract to pay the same may be reasonably inferred. The notices given by the plaintiffs may properly be considered a permission to occupy on the payment of rent. The defendants made no objection, set up no claim, and afterwards peaceably delivered possession to the plaintiffs. These circumstances, in my opinion, distinguish this case from Peter vs. Elkins; and if the plaintiffs have a right to remuneration for the use of the premises for any portion of the time from the day of sale to the time of their obtaining possession, it would, I think, be unreasonably strict to refuse it on account of the remedy adopted.

The plaintiffs claim to recover from the day of sale. They say, that on that day they parted with the use of their money, and should therefore be entitled to the rents and profits of the land. That it would be exceedingly unjust, that they should be entitled to the use of neither [461]*461the land nor money, until confirmation of the sale. Now, I cannot see, that there is any great injustice in this; the purchase is made in view of the Statute, which authorizes the money to be kept in the custody of the law, until the sale be confirmed. Such being the disposition of the money, for aught that appears, it would be an equal hardship on the debtor to deprive him of the possession of the land, until the money was applied in payment of his debt. The equity of the parties in this respect being equal, it is far more convenient not to change the possession in behalf of a purchaser, who until confirmation of the sale, it does not appear, will be certainly entitled thereto. This principle is clearly recognized by the legislature, in the “act to regulate the action for forcible entry and detainer.” Swan 417, § 19. A summary remedy to recover the possession is given in cases of “sales of real estate on execution, after such sales shall have been examined by the proper court, and the same by said court adjudged legal.”

It can scarcely be claimed, that under the system of sales under execution, established in this State, a purchaser is entitled to take possession of real estate before confirmation of the sale. And if he be not so entitled, it is difficult to show, on' what principle he can claim remuneration, for the use of the premises sold prior to that time. The ground chiefly relied on is, that under the authorities in this State, so soon as the sale is perfected by confirmation and the execution of a deed, the title relates back and is considered to have been operative and effective from the day of sale. Oviatt vs. Brown, 14 Ohio 285-294. There appears to be a good deal of plausibility in this view, and the language of some of the authorities [462]*462as to the right of a purchaser at sheriff’s sale, is quite strong; but such language must be construed in reference to the case then before the Court. There is no case in which the right of a purchaser to enjoy the rents and profits accruing before confirmation of the sale, was directly considered, unless it may be in the case of Peter vs. Elkins, in which, as already stated, the decision turned on the form of the action.

It appears to have been considered by the counsel for the plaintiffs in this case, and this consideration, indeed, forms the basis of their claim, that a legal title to land necessarily involved a right to receive remuneration for its use, by another person during the continuance of such a title.

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1 Handy 456, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heidelbach-seasongood-co-v-slader-ohsuperctcinci-1855.