Magwood v. Johnson

10 S.C. Eq. 228
CourtCourt of Appeals of South Carolina
DecidedApril 15, 1833
StatusPublished

This text of 10 S.C. Eq. 228 (Magwood v. Johnson) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Magwood v. Johnson, 10 S.C. Eq. 228 (S.C. Ct. App. 1833).

Opinion

Harper, Chancellor.

The case of Ewing v. Smith, 3 Eq. Rep. 147, which is very much the present in many of its circumstances, has settled, that a feme covert cannot dispose of, or in any manner* charge her separate estate — not even with the consent of her trustee. If issue or profits are to be paid to her separate use, she may do what she pleases with them when she receives them, but caunot dispose of them by anticipation. The Court, however, as has been decided in several eases, will charge her separate estate, if the debt has been contracted for its benefit. In a late case, that of Street v. Theus, which I decided at Sumter, I had occasioned to consider the doctrine of the liability of trust estates, for debts contracted for their benefit; and to refer to some of the rules which I supposed would govern the Court, in the application of that doctrine. In that case, I observed, “ that although it was perfectly well settled that a trust estate was liable for debts contracted for its benefit, it has not been settled that one trust estate is liable for the debts of another; or that the remainder-man is to pay the debts which were contracted for the exclusive benefit of the tenant for life.” The word ‘ estate’ has sometimes been used ambiguously. There may be various estates in the same property, and one of these is no more liable for the debts of another, than if they were estates of different property. True, where property is conveyed in trust, and particular estates are created, there may be debts chargeable on the whole estate — the particular estates as well as the remainder, and to which all shall contribute rateably. As where, at the creation of the trust, the estate is charged with a debt which falls due during the continuance of a particular estate ; or perhaps, during the continuance of a particular estate a debt may be created which shall properly be chargeable on the whole, being contracted for the benefit of the whole — such may be debts contracted for repairs and improvements. On the other hand, it cannot be doubted there may be debts of the particular estate, for which subsequent estates, or the remainder, will not be liable — such as the well known instance of interest accruing during the continuance of a life estate, which the tenant for life is bound to keep down. The accruing interest is continually due, and is a charge on the particular estate.

So in the case of a trust estate, all the charges of management* are the debts of the particular estate; taxes, current and necessary repairs, the support of slaves, if they form part of the estate; so all debts, chargeable on the estate, which were contracted for the individual benefit of the tenant for life In the case of a legal estate no one would think of the remainder being liable for the debts of the tenant for life. These must be paid, not out of the corpus of the property, but out of the profits ae-[160]*160cruing during the continuance of the estate of life. The particular estate is liable to be sold, not any part of the capital. The equity on which a creditor comes into this Court to render atrust estate liable to the payment of his debt, in this, that he has advanced his money, or given credit to effect the objects of the trust, and having accomplished the objects of the trust at his own expense, he has a right to be put in the place of the cestui que trust, or to be reimbursed out of the trust fund. If there were a trust to keep a hospital in repair, he who has made the repairs at his own expense, might have his equity to be reimbursed out of the trust fund. So, if the trusts were to pay rents and profits for the separate maintenance of a feme covert, he who had advanced his money for her separate maintenance, might have such an equity. But every estate must bear its own burthen, or instead of effecting the objects of the trust, they will be defeated. The case of Street v. Theus, to which I have alluded, was one in which the property was settled to the joint use of the husband and wife during coverture — on the death of the husband, to the wife for life, remainder on her death to the children of the marriage. The bill was filed after the death of the husband, to obtain payment out of the trusts estate, of an account for articles furnished, and advances made to the husband for the support of himself and family. Here the objects of the trust, were that during the continuance of the joint estate, the issues and profits should go to the joint issue. The advances were made by the creditor to the joint use, and I thought he could look only to the joint estate for satisfaction — that is to say, to the rents and profits which accrued during the coverture. The further objects were to secure the estate to the individual use*ofthe wife after the husband’s death, and to her children after her death.

If by making advances to the husband for the use of himself and family, the wife’s separate life estate or the capital of the property might be rendered liable, it is plain that it would be in the power of the husband and a creditor to defeat the ulterior objects of the trust altogether. It would be vain to say that the wife shall not anticipate the income of her separate property, if the husband may by exceeding his income thus anticipate it, even before it vests in possession. It is to be observed that in such cases of marriage settlement, the husband, the wife and the children, are purchasers of their several estates for valuable consideration.

I do not think the cases decided in this State inconsistent with the view I have taken. In Cater v. Eveleigh, 4 Eq. Rep., 19, a cotton saw gin was bought for the use of the wife’s separate estate — it is not stated whether she was tenant for life, or in fee. If only tenant for life, the saw gin may have been considered a permanent improvement, properly chargeable on the whole estate. — The order is general for payment out of the estate. I suppose if it were an estate for life, the effect of the order was to make it payable out of the profits of the life estate. In James v. Mayrant, 4 Eq. Rep. 591, the order was express, to pay out of the accruing profits during the continuance of the life estate. In Montgomery & Eveleigh, 1 M’C. Ch. 257, there was an estate for life, and the debt was contracted for the support of the slaves, constituting according to my view only a charge on the life estate. The order is general to pay out of the life estate. The point does not seem to have been brought before the Court, of a distinction between the liability of [161]*161the particular estate and the remainder. But I suppose the effect of the order was to make the debt payable out the rents and- profits of the life estate.

The bill in the present case is filed, as it is said, to obtain payment out of the trust estate, on the ground that the debt was contracted for its benefit. But it is to be observed in the first place, that here are two general trust estates, though both are created by the same settlement and vested in the same trustees, out of each of which various particular estates have been carved for different purposes, and subject *to distinct liabilities. It is true, that as I understand the report of the Commissioner, the whole of both estates has been sold (except one plantation) and the proceeds vested in a single fund. But the Court must dispose of the proceeds of each according to the trusts of the original settlement. There is first, the property which was Mrs. Johnston’s before her marriage, her share of her father’s estate. In this the settlement gives her a life estate, (to her separate use during coverture) with remainder to her children.

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Bluebook (online)
10 S.C. Eq. 228, Counsel Stack Legal Research, https://law.counselstack.com/opinion/magwood-v-johnson-scctapp-1833.