Hill v. Evening News Co.

4 Balt. C. Rep. 689
CourtBaltimore City Court
DecidedApril 24, 1928
StatusPublished

This text of 4 Balt. C. Rep. 689 (Hill v. Evening News Co.) is published on Counsel Stack Legal Research, covering Baltimore City Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hill v. Evening News Co., 4 Balt. C. Rep. 689 (Md. Super. Ct. 1928).

Opinion

STEIN, J.

In this case, defendant’s motion of ne recipiatur raises two questions; that of the defendant’s liability, which depends upon whether or not this suit abated on the death of the infant plaintiff before judgment, and that of parties.

The record shows: That on March 19, 1927, George Raymond Hill, the infant plaintiff, by his father and next friend, brought this suit against the defendant, a corporation, to recover damages for publishing an alleged libel ; the defendant was summoned, plead the general issue, and issue was joined. On October 10', 1927, before trial and judgment, the father filed a written suggestion of the son’s death intestate; stated, that letters of administration had not been granted; asked that he, the father, “as personal representative,” and “as successor in title,” be admitted to prosecute this suit; which did not abate on his son’s death; the defendant filed a motion of ne recipiatur to this suggestion; because the suit abated at the son’s death; and if it did not abate, the father was not a proper party plaintiff.

If the action survives, it can only be continued by an administrator of the son, duly appointed and qualified; as the father is not such administrator, the motion of ne recipiatur must be granted. If the suit abated at the son’s death, his administrator when appointed and qualified cannot continue it; so that the real question is, did the suit abate?

Counsel orally argued this question with unusual force; in their supporting briefs displayed learning and ability of very high order.

Plaintiff’s counsel contended: That the Common Law Rule, that personal actions “die with the person,” has been changed in Maryland by the Abatement Statutes, so that, save in a few instances, they do not abate at the death of the sole plaintiff before judgment; may be continued by the executor or administrator of the decedent; that while actions of slandér abate, actions of libel do not, and may be continued by the decedent’s executor or administrator.

Defendant’s counsel admit that actions of slander are excepted from the provisions of the Abatement Statutes, and are governed by the Common Law Rule, and “die with the person”; say that in these statutes the word slander is used in its then common meaning of defamation and so included libel; that it was not until long after the passage of these statutes — and in modern times that in legal language the word slander is used to mean oral defamation, so as to distinguish it from all other kinds of defamation, for which the word libel is commonly used.

[690]*690The Common Caw Rule of “actio personalis moriatur cum persona,” was in force in Maryland, until changed hy the first Abatement Statute, i. e., the Act of 1785, Chapter 80, Sec. 1, passed on March 11, 1786, under which:

“Wo action brought or to be brought in any Court of law in this State, shall abate by the death of either of the parties to such action. * * *
“And in case the plaintiff or plaintiffs in the action aforesaid shall die before the same may be tried and judgment given and such death would abate the action before this Act, the appearance of the heir, devisee, executor or administrator, as the case may be, may require, or other proper' persons to prosecute such suits shall be admitted to be entered to the same.
“* * * And all cases of death of the plaintiff after the appearance of the defendant’s heir, devisee, executor or administrator, or other person or defendant as aforesaid * * * shall be taken and considered as within the meaning and provision of this Act.”

The next Abatement Statute was the Act of 1798, Ch. 101, sub-chapter VIII, Sec. 5, which took effect on the first day of June, 1799, and restored the Common Law Rule as to actions of slander and actions for injuries or torts done the person, so that:

“Executors and administrators * * * shall have full power and authority to commence and prosecute any personal action whatsoever, at law or in equity, as the case may require, which the testator or intestate may have commenced and prosecuted, except actions of slander and for injuries done the person.”

These statutes are codified in: 2 Bagby’s Code, 1924, pp. 2371 and 2905 ; Art. 75, Sec. 29, and Art. 92, Sec. 106, p. 2905; and so far as pertinent here, are as follows, viz:

Art. 75, Sec. 29, pp. 2371-2372:

“No action of ejectment, waste, partition, dower, replevin or a>iy personal action * * * including appeals from judgments rendered by Justices of the Peace in any Court of law in this State shall abate by the death of either or any of the parties to such action * * * This not to apply to actions for injuries to the person where the defendant dies, not to actions for slander.”

Art. 92, Sec. 106, p. 2905, is as follows :

“Executors and administrators shall have full power to commence and prosecute any personal action whatever, at law or in equity, which the testator or intestate may not have commenced and prosecuted, except actions of slander; and they shall be liable to be sued in any Court of law or equity in any actions (except for slander and injuries to the person).”

The defendant’s liability in this case depends upon the meaning of the word slander in the Acts of 1786 and 1798, supra; that meaning is to be found in the ancient authorities in force when these Acts were passed.

They show that then slander was used by judges and law writers to mean all kinds of defamation. Later authorities show that the use of the word slander meant oral defamation only, so as to distinguish it from libel, which included all other kinds — was of a much later and modern development.

This is shown in Johnson vs. Haldeman, 102 Ky. 163. Burnam, J. — “The only question in this case is whether an action for libel survives the death of the plaintiff. Appellees were sued by Andrew Johnson for publishing an allegel libel against him. Before trial, he died, and his administratrix moved the Court to revive the action in her name. This the Court refused to do, holding that the action was embraced by the provisions of Section 10 of the Kentucky Statutes, under the word ‘slander.’ By that section, actions for slander do not survive. As libel is not named in that section, the question is, does the word ‘slander’ embrace libel? The word ‘slander’ is the general and original word for all kinds of defamation. One can be defamed by words spoken, words written, or by signs or pictures, and, when so defamed, it is called slander; and the word ‘slander,’ in the statute, we think, was intended to embrace all these varieties of defamation. There is nothing in the statute which shows that the word was intended to be limited in its meaning to oral sla’nder. Webster defines ‘slander’ as defamation generally, whether oral or written, but goes on to say that in modern usage it has been limited to defamation by words spoken. Bae. Abr., says: ‘Slander is the publishing of words, in writing or by speaking, by reason of which the person to whom they relate becomes liable to suffer some corporal punishment.’ [691]*691Esp. N. P.

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Bluebook (online)
4 Balt. C. Rep. 689, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hill-v-evening-news-co-mdcityctbalt-1928.