Jarvis v. Brooks

23 N.H. 136
CourtSuperior Court of New Hampshire
DecidedDecember 15, 1851
StatusPublished

This text of 23 N.H. 136 (Jarvis v. Brooks) is published on Counsel Stack Legal Research, covering Superior Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jarvis v. Brooks, 23 N.H. 136 (N.H. Super. Ct. 1851).

Opinion

Perley, J.

At law, until equity interfered and introduced another rule, the creditor of one partner might take his share in the partnership goods on a fi. fa., and sell that share as if the partner had been tenant in common. The vendee under the sheriff’s sale, became tenant in common with the other partners, and was not subject to the partnership account. He took, not his debtor’s share of the surplus, after the partnership liabilities were satisfied, but an absolute undivided share in the chattel sold. Heydon v. Heydon, Salkeld, 292; Dutton v. Morrison, 17 Ves., 205.

In the administration of the English bankrupt laws, the rule was early established that the creditor of one partner could take nothing out of the joint estate for the satisfaction of his debt, till all the partnership debts were |>aid; and this doctrine was adopted in equity as a general rule, by which a preference was secur[142]*142ed to the partnership creditor, over the partnership funds, for the satisfaction of their debts. In England, courts of law now recognize the principle to some extent and for some purposes, but the rule is said to be there generally disregarded at law. Waters v. Taylor; 2 Vesey & Beames, 301; 1 Story on Equity, 625.

As the creditors of the partnership are preferred, in the application of the partnership estate, so the creditor of the individual partner is preferred as it respects the separate property. In case of joint traders becoming bankrupt, the joint creditors shall first be paid out of the partnership effects, and the separate creditors, out of the separate effects, and if any surplus of the partnership effects, after all the partnership debts are paid, the separate creditors to come in, and so, vice versa, the partnership creditors to come in on a surplus of the separate estate.” Ex parte Cook, 2 P. Wms., 500; Ex parte Crowder, 2 Vernon, 706; Ex parte Rowlandson, 3 P. Wms., 408; Ex parte Baudier, 1 Atkins, 98; Gray v. Chiswell, 9 Vesey, 118.

The preference allowed to the separate creditor, over the separate estate of his debtor, appears to have been introduced, at the same time with the corresponding preference given to the partnership creditors, over the partnership estate. They are reciprocal rules, and dependent on the same equitable principle. The rule, and the equitable grounds of it, are thus stated by counsel in Grey v. Chiswell, 9 Vesey, 120. “ The court makes a just arrangement between both estates, and both parties are before the court, but there the joint creditors cannot have recourse to the separate fund, till the separate creditors are paid; and the course of proceeding is founded on, not merely convenience, but substantial justice. The joint creditors hence increase the joint fund, and those who make advances on the separate credit, having created the separate fund, the natural justice is, that the funds so constituted shall be applied to the respective demands.”

It would seem to have been sometimes supposed, that the claim of the separate creditor to a preference over the separate estate, was denied and disallowed in the time of Lord Thurlow. Allen v. Wells, 22 Pick. Rep., 453.

[143]*143This opinion, We think, has gone on a misapprehension of the design and effect of the orders made on this subject, by that chancellor. In order to apply the equitable rule for marshalling the assets of the partnership and of the individual partners, and assigning them to the respective classes of debts, it was necessary, of course, that an account should be taken of the joint, and of the separate estates. If a joint commission issued against the partners, such accounts were taken without special application to the court, and the respective estates were applied to the claims against each, according to the rule above stated. Ex parte Baudier, 1 Atkins, 98; 1 Cook’s Bankrupt L., 9.

But where the commission was against one of the partners, no account could be taken of the joint estate, under that commission, without a bill in equity, brought for that purpose. It is said, that, in early times, a joint commission was sometimes sued out, after a separate commission, and both were allowed to go on together ; but of late two commissions are not permitted at the same time. Murray v. Murray, 5 Johns. Ch. Rep., 76.

During and before. the time of Lord Hardwielce, the joint creditor was allowed to prove his debt under the separate commission, for the purpose of objecting to the allowance of a certificate, but not to' take a dividend; and under this rule, if the joint creditor desired an account to be taken of the joint and several estates to be distributed according to the rule in equity, the burden was thrown upon him, the joint creditor, to file his bill, and bring before the court the solvent partner, and the assignees of the bankrupt, and hence the account of the joint estate taken in their presence. Murray v. Murray, 5 Johns. Ch. Rep., 72.

In 1785, Lord Thurlow changed this rule, and ordered that, on petition of a joint creditor, he should be allowed to prove his debt and take dividends under a separate commission, pari passu with the separate creditor. Ex parte Hogdson, 2 Brown, 5.

The chancellor, sitting in bankruptcy, had both a legal and equitable jurisdiction. The commission was considered to be in the nature of an execution; and at law a judgment, recovered by a joint creditor, was regarded in the same light as a judgment [144]*144recovered by a separate creditor, and satisfied in the same way out of tbe separate property. If the chancellor, therefore, in making these orders chose to consider himself as acting in the exercise of his legal jurisdiction, he could recognize no distinction between the joint and separate creditors in their claim to be satisfied out of the separate estate. The legal right of the joint creditor was clear; but equity interfered, when application was made to that jurisdiction, by marshalling the joint and separate assets equitably between and among the joint and separrate creditors. Murray v. Murray, 5 Johns. Ch. Rep., 72.

As a rule of practice, Lord Thwrlow, in the order allowing the joint creditor to prove his debt under the separate commission, thought it expedient, as matter of convenience, to look to the legal, rather than the equitable, rights of the parties, and in this preliminary order to place the joint creditor on his legal footing of equality with the separate creditor. But this change, in a mere matter of practice, had no effect to change the substantial and ultimate rights of joint and separate creditors to a distribution of the respective funds, according to the general rule in equity, which had there been recognized and established for a century. Upon a proper application to the equitable jurisdiction of the chancellor, the separate creditor had the benefit of of that rule on exactly the same principle as in the former practice. The change in practice merely shifted the burden of bringing a bill to take the joint account from the joint creditor to the assignees under the separate commission.

The case of Ex parte Hodgson, is meagerly reported in 2 Brown. A much more satisfactory account of it is given by Lord Eldon in Dutton v. Morrison, 17 Vesey, 207, and by that account it appears that Lord Thurlow

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Related

Murray v. Murray
5 Johns. Ch. 60 (New York Court of Chancery, 1821)
Reed v. Shepardson
2 Vt. 120 (Supreme Court of Vermont, 1829)

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Bluebook (online)
23 N.H. 136, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jarvis-v-brooks-nhsuperct-1851.