Hoopes Bros. v. McMenamin

5 Pa. D. & C. 60, 1923 Pa. Dist. & Cnty. Dec. LEXIS 149
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedOctober 29, 1923
DocketNo. 34
StatusPublished

This text of 5 Pa. D. & C. 60 (Hoopes Bros. v. McMenamin) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoopes Bros. v. McMenamin, 5 Pa. D. & C. 60, 1923 Pa. Dist. & Cnty. Dec. LEXIS 149 (Pa. Super. Ct. 1923).

Opinion

Williams, J.,

The defendant, the wife of Michael J. McMenamin and a resident of the village of Merion, in the Township of Lower Merion, this county, in her affidavit of defence, in effect, admits that on the 21st day of November last she signed a spring box order, wherein she asked the plaintiff, a domestic corporation, engaged in the growing of trees and plants at the Borough of West Chester, Chester County, during March, April or May of this year, for the improvement of her property, to send her and deliver at Cumberland, Maryland, station, certain nursery stock, described as 198 peach trees, of seven different kinds, 199 grape vines, of three separate varieties, and 300 raspberry bushes, for which she agreed to pay in cash $389.33, and stated that if, within five days after the arrival of the stock, she failed to call for it, she thereby authorized the plaintiff, for her and on her account, to deliver the stock on her premises and charge her with the cost of delivering.

In the box order the plaintiff agreed that the stock should be of first class quality and delivered in good condition.

The defendant denies that the plaintiff, in accordance with the above written contract between it and her, sold and delivered the stock as ordered, at the time and place and in the quantities and varieties specified by her in the order and that on May 4th the goods were consigned to her and arrived at Cumberland station. She avers that, on the contrary, she did not designate the manner of the shipment of, or select the carrier for, the stock; tkat the [61]*61plaintiff did not inform her when or from where the goods would be shipped, or when they would arrive at Cumberland; that, not being informed as to the time or manner of shipment or the name of the carrier of the goods, she made frequent inquiries at Cumberland station, only to be there told that the merchandise had not yet arrived; and that, after weeks of delay, she did, finally, find out that the merchandise had reached Cumberland, whereupon she had made an inspection of the goods and, as a result thereof, then notified the plaintiff that, due to the delay in furnishing her'with a bill of lading for the stock and delivering the goods to her, the stock was in a defective condition.

The defendant avers, further, that at no time did she receive a bill of lading for the merchandise and that the stock was never delivered.

It does not appear from the pleadings or record that the rule for judgment was ever served upon the defendant, but, nevertheless, the rule was orally argued at bar before the court in banc at the stated session of the court for argument held on the second Monday of October. Although three weeks have since elapsed, as yet the court has not been favored with a brief from the attorney for the defendant. The failure of counsel so to do constitutes a plain and direct violation of our Rule 25, which provides that, in all arguments before the court in banc, or before the judges at chambers, counsel for the respective parties shall submit to the court a statement of the points in controversy with a brief of authorities.

The proper determination of the principal questions here involved necessitates a consideration of the provisions of the Sales Act (Act of May 19, 19Í5, P. L. 543-566), whereof section 74, interpretation shall give effect to purpose of uniformity, says that the act shall be so interpreted and construed, if possible, as to effectuate its general purpose to make uniform the law of those states which enact it.

If these uniform acts are construed in the several states adopting them according to former local views upon analogous subjects, the desired uniformity will be missed and, instead, there will be erected upon the foundation of uniform language separate legal structures as distinct as were the former varying laws: Commercial Bank v. Canal Bank, 239 U. S. 520-528 (1916), Hughes, J.

Thus admonished by statute and enlightened by decision, we shall consider chiefly only those authorities having special reference to the Uniform Sales Act.

Rule 4 of section 19, rules for ascertaining intention, of the Sales Act of May 19, 1915, P. L. 543, 548-9, declares that, unless a different intention appears, one rule for ascertaining the intention of the parties as to the time at which the property in the goods is to pass to the buyer is that: first, where there is a contract to sell unascertained or future goods by description and goods of that description and in a deliverable state are unconditionally appropriated to the contract, either by the seller with the assent of the buyer, or by the buyer with the assent of the seller, the property in the goods thereupon passes to the buyer, and that such assent may be expressed or implied and may be given either before or after the appropriation is made; and, second, where, in pursuance of a contract to sell, the seller delivers the goods to the buyer, or to a carrier or other bailee (whether named by the buyer or not), for the purpose of transmission to, or holding for, the buyer, he is presumed to have unconditionally appropriated the goods to the contract, except in the cases provided for in the next rule and in section 20, and that this presumption is applicable, although by the terms of the contract the buyer is to pay [62]*62the price before receiving delivery of the goods and the goods are marked with the words “collect on delivery,” or their equivalent.

Section 20, reservation of right of possession of property when goods are shipped, of the Sales Act of May 19, 1915, P. L. 543-549, to which the exception noted in Rule 4, supra, refers, concerns itself with four separate and distinct sets of conditions no one of which bears any relationship to the issue here presented.

Rule 5 of section 19, supra, which) constitutes the second exception mentioned in Rule 4, supra, is, however, that, if the contract to sell requires the seller to deliver the goods to the buyer, or at a particular place, or to pay the freight or cost of transportation to the buyer, or to a particular place, the property does not pass until the goods have been delivered to the buyer, or reached the place agreed upon.

It is to be observed that this rule does not prescribe that the property passes when the goods have been delivered to the buyer, or reached the agreed-upon place, but that property does not pass until the happening of the prescribed eventuality. It does not fix a time when title passes, but only a time before which it cannot pass. All it does is to fix the hithermost limit of time within which title may pass. Upon when, beyond that limit, title shall pass the rule is significantly silent.

Of course, this rule, together with the several other rules prescribed by the ' 19th section for ascertaining the intention of the parties as to the time at which the property in the goods is to pass to the buyer, is a mere rule of presumption and, if a contrary intention appears, must, by the language of the section itself, give way to the intention so appearing: Funt v. Schiffman, 187 N. Y. Supp. 666-668 (1921), Lehman, J. (S. C., A. T., 1st Dept.).

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Bluebook (online)
5 Pa. D. & C. 60, 1923 Pa. Dist. & Cnty. Dec. LEXIS 149, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoopes-bros-v-mcmenamin-pactcomplmontgo-1923.