In re the Assignment of Commercial Bank

2 Ohio N.P. 170
CourtHamilton County Court of Insolvency
DecidedAugust 15, 1895
StatusPublished

This text of 2 Ohio N.P. 170 (In re the Assignment of Commercial Bank) is published on Counsel Stack Legal Research, covering Hamilton County Court of Insolvency primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Assignment of Commercial Bank, 2 Ohio N.P. 170 (Ohio Super. Ct. 1895).

Opinion

McNEILL, J.

On March 27, 1895, at 8.48 o’clock p. m., the Commercial Bank made an assignment for the benefit of its creditors, under the provisions of the Ohio insolvent laws.

A number of intervening petitions have been filed herein asking for return of deposits, proceeds of drafts and checks, etc., deposited in the bank just prior to its failure, by the several petitioners; and others asking that money deposited in the bank maybe set off against paper held by the trustees against the several petitioners, etc. These pelilions were all heard together upon testimony and submitted to the court for determina[171]*171tion. The evidence submitted shows that on the morning of March 27, 1895, the date of the assignment, a committee from the Cincinnati clearing house visited the banlc and made an investigation as to its solvency. This investigation was brought about by the fact that the bank had been slow in meeting its obligations to the clearing house, and a current rumor in banking circles that the bank was in distress. The committee finished its investigation at 1.30 to 2 o’clock p. m. The result was that the clearing house refused to grant the bank any further assistance, and all the “hold over” checks of the bank held by other banks were sent to the clearing house that day. The bank was informed of the action of the clearing house at 2.15 to 2.20 o’clock p. m. on that day. The result was that the bank was unable to get through the clearing house by many thousand dollars, and the assignment was made the same afternoon. The bank is shown to be badly insolvent. It further appears that the bank had not suffered any recent serious losses, and that its condition at the time of its failure was not materially different from what it had been for more than a year prior thereto. So that the bank had been in a badly insolvent condition for more than a year prior to the assignment, and there can be no question but that the officers of the bank knew of its condition during that time. A careful examination of the affairs of the bank shows that, reckoned upon a fair business basis, the liabilities of the bank exceeded its assets by at least $200,000, and yet during all this time the doors of the bank were open, deposits were received and business carried on with its customers, all of whom were in total ignorance of its condition. No matter what the actual intention of the officers of the bank might be, in law their action was fraudulent toward every person whose money was received while the bank was in that condiion.

In Anonymous Case, 67 N. Y. 598, the Supreme Court of New York decided that “in the case of bankers, where greater confidence is asked and reposed, and where dishonest dealings may cause widespread disaster, a more rigid responsibility for good faith and honest dealing will be enforced than in the case of merchants and other traders;” and “that a banker, who is to his own knowledge, hopelessly insolvent, can not honestly continue his business and receive the money of his customers; and although having no actual intention to cheat 'and defraud a particular customer, he will be held to have intended the inevitable consequences of his act, i. e., to cheat and defraud all persons whose money he receives, and Avhom he fails to pay before he is compelled to stop business.” This language is quoted with approval by Chief Justice Fuller in his opinion, in St. Louis, etc., Ry. Co. v. Johnston, 133 U. S. 566, and by Andrews, J., in his opinion in Cragie et al. v. Hadley, 99 N. Y. 131.

Holding, therefore, as I do, that the Commercial Bank had no right to continue business after its insolvent condition became known to its officers, and that its condition was known to said officers for more than a year prior to the assignment, it follows that, although its officers may have had no actual intent to defraud any particular customer, they will be held to have intended the natural consequences of their acts, i. e., to defraud all persons whose money the bank received and failed to pay before it stopped business. It follows, therefore, that if the money deposited by a customer, or any person, has not lost its identity, it may be recovered back.

But in case the identity of the money deposited has been lost, keeping in view the fact that the bank was at the time of the failure in no worse condition than it was for months before, I can see no reason why money left there by another customer should be taken in its stead. Hence there should be no distinction between depositors, the identity of whose money [172]*172lias been lost, and the mere fact that one deposit was a little nearer to tbe time-of the failure of the bank should make no difference. As to all such parties, Equity is equality.” Morse on Banking, sec. 680.

I will now consider the several cases presented separately:

Money Collected by the Assignee.

The petition of Rebecca E. Thomas alleges — and the evidence submitted sustains the allegations — that having received from a party in the West a draft for $500.00 on a bank in New York, she deposited the same in the Commercial Bank on the day it failed. The draft was forwarded to New York, and was duly paid and the proceeds came into the hands of the assignee of the bank after his appointment, and are now in the bands of the trustees. Under the authorities above cited, Mrs. Thomas is entitled to have said proceeds paid over to her. Ben B. Dale, attorney.

Money‘Collected by the Bank Before the Assignmnet.

The petition of Dittoe & Wisnell is for the proceeds of a check of Wm. Gerdes, drawn on the bank of S. Kuhn & Sons, to their order, and which they deposited in said bank on the day it failed. The proceeds were appropriated by the bank before the assignment, and did not come into the hands of the trustees. The prayer of the petition for an order requiring the trustees to repay the money is refused. Greene Fenley, attorney.

Money Deposited on the Day of the Assignment and Mingled with the Bank Funds.

The petition of the Union News Company is for the return of $825.50 in money deposited in the said bank on the day of the failure. The money has not been identified or traced into the hands of the trustees. The prayer of the petition for repayment of the money is refused. Joseph Cox, Jr., attorney.

Money Checked Against in Payment of a Draft.

The petition of J. W. S. Evans shows that on the day said bank failed he deposited therein $150, and at the same time he purchased from the bank a draft on New York for $125, which was returned unpaid. The money deposited out of which the draft was purchased has not been identified, and I can see no reason why the application of a part of it to the purchase of a draft can make any difference. It is the right to reclaim his own, no matter what form the transaction may have assumed, that governs. Hence, not having identified his money, or traced it into the hands of the trustees, the prayer of the petition for the repayment of the money is refused. Ben B. Dale, attorney.

Drafts Purchased by Check on the Bank.

The petition of A. C. Barney, agent for Ellen M. Pike and others, is for the repayment of $5,000, being the amount of three drafts on New York for $500, $1,500 and $8,000, respectively, purchased of the Commercial Bank on March 27, the date of its failure. Barney, as such agent, was a depositor in said bank, and paid for the drafts by checks on his account with the bank.

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Related

St. Louis & San Francisco Railway Co. v. Johnston
133 U.S. 566 (Supreme Court, 1890)
Cragie v. . Hadley
1 N.E. 537 (New York Court of Appeals, 1885)
Anonymous
67 N.Y. 598 (New York Court of Appeals, 1876)

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Bluebook (online)
2 Ohio N.P. 170, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-assignment-of-commercial-bank-ohctinsolvhamil-1895.