In re certain taxpayers of the Town of Gorham

43 How. Pr. 263
CourtNew York County Court, Ontario County
DecidedMay 15, 1872
StatusPublished

This text of 43 How. Pr. 263 (In re certain taxpayers of the Town of Gorham) is published on Counsel Stack Legal Research, covering New York County Court, Ontario County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re certain taxpayers of the Town of Gorham, 43 How. Pr. 263 (N.Y. Super. Ct. 1872).

Opinion

Wm. H. Smith, C. J.

—On the 15th day of April, 1872, a petition was presented to me, as county judge, in the above matter, upon which an order was made in pursuance of the requirement of the provisions of chapter 925, of the session laws of 187Í, to take the proofs of the facts set forth in the petition on the 2d day of May, instant.

[264]*264On the said 2d day of May, Hon. E. B. Pottle and A. McDonald, Esq., appeared as counsel for the petitioners, and Hon. H. L. Comstock, appeared as counsel for contestants, Mason Beed, Addison Stearns and Charles Middaugh. The evidence closed on the 11th day of May,.instant, and on the same day was submitted to me, together with objections raised by contestant’s counsel for decision.

The conclusion to which I have arrived, renders it unnecessary for me to, determine whether the consent of a majority 'of the taxpayers of said town has been obtained, for the reason that two óf the objections raised at the threshold'of the proceedings, are, in my judgment, fatal to the ■petitioners. Those objections are as follows:

1st. The petition does not state that the Geneva and Southwestern Railway Company is a corporation in this state. ,

2d. The petition contains a condition which renders the petition void.

To understand the force of these objections, it will be nec'essary to refer to the petition addressed to the county judge. The language of the petition is as follows:.

■ “The undersigned respectfully represent that they area, majority of the taxpayers of the town of Gorham, in the county of Ontario, who are taxed for property (not including those taxed for dogs, or highway-tax only), upon the last preceding tax list of said town of Gorham; that they are assessed and taxed for, or represent a majority of the taxable property upon said tax list, and that they desire the said town of Gorham shall create and issue its bonds to the amount of fifty thousand dollars, and invest the same, or the proceeds thereof, in the stock of the Geneva and Southwestern Railway Company.”

The condition of this petition is—If the said “ The Geneva and Southwestern Railway Company” accept the subscription to its. stock and payment therefor by the bonds or proceeds as authorized by this petition, they thereby forfeit all right [265]*265and hereby agree to make no claim to any bonds of said town of Gorham, or the proceeds thereof, by virtue of a certain other petition oi the taxpayers of the said town, to issue the bonds of said town for a like amount and purpose, which petition was filed with the county judge of Ontario county, October 28, A.D. 1871. This petition is made under and in pursuance of chapter 925 of the laws of 1871, and all acts of which it is amendatory.

The language of section 1, of the statute above referred to, so far as it relates to what must be set forth in the petition, is as follows:

“ Whenever a majority of the taxpayers of any municipal corporation in this state who are taxed or assessed for property, not including those taxed for dogs, or highway tax only, upon the hist preceding assessment roll or tax list of said corporation, and who are assessed or taxed, or represent a majority of the taxable property upon said last assessment roll or tax list, shall make application to the county judge of the county in Which such municipal corporation is situate, by petition, verified by one of the petitioners, setting forth that they are such majority of taxpayers, and are taxed or assessed for, or represent such a majority of taxable property, and that they desire that such municipal corporation shall create and issue its bonds to an amount named in such petition, and invest the same, or the proceeds thereof, in the stock or bonds (as said petition may direct) of such railroad company in this state, as may be named in said petition, it shall be the duty of the said county judge to order,” &c.

The language of said section, so far as it relates to the conditions which the- petition may contain, is as follows :

“ The petition authorized by this section, may be absolute or conditional ; and if the same be conditional, the acceptance of a subscription founded on such petition, shall bind the railroad company accepting the same to the observance of the condition or conditions specified in such petition ; provided, however, that non-compliance with any condition inserted in [266]*266such petition shall not in any manner invalidate the bonds created and issued in pursuance of such petition.”

The above objections will be examined in their order.

1st. It will be seen that The Geneva and Southwestern Railway Company” is not set forth in the petition as. being a corporation in this state. It nowhere appears in the petition that it is in this state ; indeed, its locality is not stated at all Courts cannot take judicial notice of "the location of corporations, unless the same is at least alleged.' It cannot be presumed that the Geneva and -Southwestern Railway Company” is a corporation in this state, by the mere naming the company. • , ■

• It is a well settled principle that in actions at law where the .complaint sets forth the name of the corporation and describes it’as a corporation in this state, duly organized under the laws thereof, that, however truthful this allegation and description may be, yet if the answer denies it, however false that answer may be, the court cannot take judicial notice of the existence of the corporation.

In such case, the popularly well known corporation, known as the New York Central and Hudson River Railroad Coma pany, cannot, in an action at law, be presumed by the court to be a corporation in this state; in other words, the courts cannot, in such, case, take judicial notice of its existence. ' I do not understand this proposition Was disputed on the argument, but it was contended by petitioners’ counsel that if the petition alleged a railroad corporation which is in fact in this state, though not so stated in the petition, it is sufficient, and that fact could be proved aliunde the petition.

It muát be remembered that this statute is in derogation of the common law, and therefore, must be strictly construed, as the -courts have frequently held. If it would seem hypercritical to hold, even under the rule of strict construction, that the petition is ■ invalid, because it does not set forth a corporation in this state, in terms. Yet, by another rule of construction, prevailing in criminal cases, which in principle [267]*267is applicable here, the corporation must be set forth in the petition as being in this state, because it 'is, at least in the enacting clause, provided that such company shall be a railroad company in this state. By this proviso, so to speak, no company other than a railroad company in this state, can receive the benefit of this act.

It is a well settled principle that—“ Where the proviso adds a qualification to the enactment, so as to bring a case within it, which, but for the proviso, would be without the statute,-.the indictment must show the case to -be within the proviso” (Wharton’s American Criminal Law, § 379, and cases cited.

But it is enough for me to say, that this question- has been -decided in the third judicial department, in the case of The People ex rel. Hoag agt. Peck, 4 Lansing, 532).

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43 How. Pr. 263, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-certain-taxpayers-of-the-town-of-gorham-nyontarioctyct-1872.