Household Finance Corp. v. Goodman

16 Mass. App. Dec. 145
CourtMassachusetts District Court, Appellate Division
DecidedOctober 22, 1958
DocketNo. 455281
StatusPublished

This text of 16 Mass. App. Dec. 145 (Household Finance Corp. v. Goodman) is published on Counsel Stack Legal Research, covering Massachusetts District Court, Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Household Finance Corp. v. Goodman, 16 Mass. App. Dec. 145 (Mass. Ct. App. 1958).

Opinion

Shamon, J.

Action of contract or tort in two .counts. Count one alleges the defendant obtained the sum of $446.58 by false pretenses and representations. Count two alleges the defendant secured the sum of $446.58 from it by means of a promissory note signed by him, but which was loaned to him by reason of the false pretenses and representations made to the plaintiff by the defendant inducing the loan. In addition to the plea of general denial and payment, the defendant’s answer set forth that he was adjudicated a bankrupt; that the plaintiff’s claim was properly listed in the bankruptcy schedules filed by him; that the claim is one that is dischargeable in bankruptcy; that neither the plaintiff nor its representative objected to the discharge; and that the defendant was discharged in bankruptcy and therefore owes the plaintiff nothing.

Permissible findings indicated that the note representing the loan to the defendant was dated August 10, 1956 and was made after the defendant orally represented his financial condition to the plaintiff; that these rep re[147]*147sentations, although written down by the plaintiff in a formal application, preceding said loan to the defendant, was not signed by the defendant The only evidence of any representations of the defendant’s financial condition prior to and at the time of the loan to him was that they were made orally.

It was found that the plaintiff filed a petition in bankruptcy on February 26, 1957 in the United States District Court for the District of Massachusetts. There was evidence showing that prior to August 10, 1956 the defendant owed his creditors an amount far in excess of the amount represented to the plaintiff at the time he secured the loan, and that the plaintiff relied on the oral statements as to the defendant’s financial status, without which representations the loan would not have been granted. The defendant presented no evidence and rested on the plaintiff’s case.

At the .close of the evidence the plaintiff filed the following Requests for Rulings:

“1. The evidence is sufficient to warrant a finding for the plaintiff.
2. The evidence is insufficient to warrant a finding for the defendant.
3. Upon all the evidence the finding should be for the plaintiff and the plaintiff submits that the defendant’s discharge in bankruptcy does not affect the debt owed by him to the plaintiff since it is a liability for obtaining money or property by false pretenses and false representations. 11 USC c. 3, §35 (17).
4. Section Fourteen of the United States Code, Title n, c. 3, §32, which reads in part; “The Court shall grant the lischarge unless satisfied that the bankrupt has — (3) obtained money or property on credit, or obtained an extension [148]*148or renewal of credit, by making or publishing or causing to be made or published in any manner whatsoever, a materially false statement in writing respecting his financial condition”; n ÜSC, c. 3, §35 (17) which reads in part, “a. A Discharge in bankruptcy shall release a bankrupt from all of his provable debts, whether allowable in full or in part, except such as — (a) are liabilities for obtaining money or property by false pretenses or false representations”, — are separate and distinct remedies available to creditors against their debtors who have filed petitions in bankruptcy, said sections serving two different purposes, and should not therefore be construed in connection with one another.
5. One who obtains money or property by false pretenses or false representations even though orally made and not in writing is not released from liability on his debt and his discharge in bankruptcy shall be no defense to an action brought for recovery thereof.
6. If the Court finds as a fact that the defendant obtained a loan from the plaintiff and that the plaintiff parted with money or property in reliance upon and belief in the truth of certain oral representations of fact relating to the defendant’s financial condition, when in fact the said money or property was obtained by false pretenses or false representations even though orally made and not in writing, then the Court should rule as a matter of law — that the debt in question is not affected by the defendant's discharge in bankruptcy.
7. False pretenses or false representations made by a person in obtaining money or property need not be in writing in order for the debt for said money or property to be unaffected by a discharge in bankruptcy.
8. A discharge in bankruptcy shall not release a bankrupt from his liability on a debt which was incurred and obtained by false pretenses or false representations orally made.
[149]*1499. The evidence is sufficient to warrant a finding that the plaintiff was damaged by the defendant’s false pretenses and false representations.
10. The plaintiff is entitled to recover not only what it has lost but what it would have realized from the transaction had it been as represented. Forman v. Hamilburg, 300 Mass. 138, 143.
11. The plaintiff may sue on the contractual obligation, where money or property has been obtained by false pretenses and false representations.”
The court declined to rule on any of the requests, but stated that, “I decline to pass on these rulings as I have indicated in my findings of fact the legal rule on which I have predicated my findings for the defendant.”

The court made the following findings and rulings:

“I find that the defendant obtained money and/or property by false pretenses and false representations that were not in writing; that the plaintiff made said loan and accepted the defendant’s promissory note in reliance upon and belief in the truth of certain oral representations of fact which the defendant made to the plaintiff, including a representation that he, the defendant, at the time of this loan had no other debts than those aggregating $368.36, when in fact he had debts far in excess of the amount stated.
However, I have construed subsection 17 of the U. S. Code, Title n, Chapter 3, Sec. 35 in connection with subsection 14 of the same section of the U. S. Code and have denied plaintiff recovery by reason of the discharge in bankruptcy of the defendant. I further rule that this is a debt which does not come within the meaning of subsection 17 aforesaid since the false pretenses and false representations were not in writing.
I find that the statements made by the defendant were materially false but since they were not made in writing, the [150]*150debt is unenforceable by reason of the defendant’s discharge in bankruptcy.
I find for the defendant.”

The single issue presented is whether a discharge in bankruptcy releases a bankrupt from a debt incurred by means of false representations if such false representations were oral. In other words, must the false representations be in writing in order to subject the bankrupt to liability regardless of the discharge granted to him by the bankruptcy court?

The issue raised by the pleadings and facts is to be decided by reference to the United States Bankruptcy Act— (11 U.S.C. c.

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Bluebook (online)
16 Mass. App. Dec. 145, Counsel Stack Legal Research, https://law.counselstack.com/opinion/household-finance-corp-v-goodman-massdistctapp-1958.