Mayfield Heights v. Gates Mills

188 N.E. 758, 46 Ohio App. 349, 15 Ohio Law. Abs. 664, 1933 Ohio App. LEXIS 373
CourtOhio Court of Appeals
DecidedOctober 9, 1933
Docket13036-13039
StatusPublished

This text of 188 N.E. 758 (Mayfield Heights v. Gates Mills) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mayfield Heights v. Gates Mills, 188 N.E. 758, 46 Ohio App. 349, 15 Ohio Law. Abs. 664, 1933 Ohio App. LEXIS 373 (Ohio Ct. App. 1933).

Opinion

*666 OPINION

By LEVINE, J.

There can be no dispute but that the sole authority to make a determination in the matter of apportionment of the inheritance taxes accruing upon the estate of a deceased person is vested in the Probate Court. The Common Pleas Court is not authorized in- an original action to make such a determination. If upon such determination by the Probate Court, an appeal is had to the Common Pleas Court, or error proceedings are prosecuted to it from, the order of the Probate Court, then, and only then, is the Common Pleas Court vested with authority to make a finding, as to the apportionment of the inheritance taxes.

When the Probate Court made its order on May 2, 1929, which found that the Village of Mayfield Heights was entitled to its portion of the inheritance tax of the estate of Matthew Andrews,•’ no exceptions were taken, no appeal was prosecuted ’ and no error proceedings were prosecuted to the Common Pleas Court.- If the order of the Probate Court stood in its Original form, the Common Pleas Court would' be without power to change - it in an original action. In other words if the original order of -the Probate Court stood undisturbed, the present action brought by the Village of- Gates Mills against the Village of Mayfield Heights for money had and- received could not have been maintained.- The only possible-basis for the judgment entered in the present case by the Common Pleas Court would be that at a later date,' to-wit, April 9, 1931, the Probate Court changed the former order and made a determination that the inheritance tax fund formerly awarded to the Village of Mayfield Heights is awarded to the Village of Gates Mills.

..Two major questions are presented to us for our consideration. (1), was the order of the Probate Court entered on April 9, 1931, which declared its former determination in favor of Mayfield Heights Village to be a mistake and determined that .the fund belonged to the Village of Gates Mills, made within a proper exercise of the judicial power vested in the Probate Court? In other words, is it a valid order or is it a mere nullity? (2), assuming that the order of the Probate Court entered April 9, 1931, was a valid order, could this action be maintained as for money had and received notwithstanding the fact that the money was paid by the county auditor and county treasurer to the Village of Mayfield Heights under the order of the Probate Court entered May 2, 1929, which made a determination in. favor of the Village of Mayfield Heights? In other words, was the money received by the Village of Mayfield Heights under a mistake of .law so as to bar this action?

The. answer to the first question involves a discussion as to the power and jurisdiction .of the Probate Court -to modify or correct an entry more than two years after the same was made, without notice to the party substantially affected by the modified entry. In Johnson v Johnson, 26 Oh St 357 it is held:

“It is the settled doctrine that the Ohio Probate Court cannot vacate its entries unless -expressly authorized by statute.”

Davis v Davis, 11 Oh St 386 is to the same effect.

*667 The new Probate Code expressly fixes definite terms for the Probate Court. Under its provisions a vacation of former entries is now possible in the Probate Court the same as in other courts. It must, of course, be in accordance with the usual rules, i.e., by motion during the same term and by petition after term. There is considerable confusion on the question as to whether or not the Probate Court under the former code had any fixed terms. As we gather from the various adjudicated cases the Probate Court under the former code had terms for adversary matters and no terms as to ex parte matters. The determination as to the apportionment of the inheritance tax which attaches to the estate of deceased persons, is an ex parte matter adjudicated by the Probate Court. There is no' statutory authority enabling the Probate Court to change or modify the same at a subsequent term.

It is our opinion that under the old code the only method by which such order of determination of the apportionment of inheritance taxes made by the Probate Court could be attacked is by either appeal or error proceedings to the Common Pleas Court made within the time prescribed by law. The attempted order of April 9, 1931,, which changed and modified the former .entry made on May 2, 1929, by determining that the former order was a mistake and that the Village of Gates Mills is entitled to the inheritance taxes was, in our opinion made without any authority in law. It is a mere nullity, and as such has no legal effect. Especially is this true, in view of the fact that the subsequent entry of April 9, 1931 was made without any notice whatsoever to the Village of Mayfield Heights whose interests were substantially affected by the order.

The answer to question two, which assumes that the order of the Probate Court entered April 9, 1931, was a valid order, deals with the nature and essence of contracts denominated quasi contracts, and also with the question of whether or not an action like the action at bar can be maintained wherein the payment was made by authority of an order of a court of competent jurisdiction under the mandate of General Code of Ohio.

Quasi contracts are also called constructive contracts or contracts implied in law. In the leading Supreme Court case of Columbus H. Valley & T. R. Company v Gaffney, 65 Oh St 104, the court said:

“There is some confusion in the statement of the law applicable to what are frequently called implied contracts, arising from the fact that obligations generically different have been classed as such, not because of any real analogy, but because where the procedure of the common law prevails, by the adoption of a fiction in pleading — that of a promise where none in fact exists or can in reason be supposed to exist — the favorite remedy of implied assumpsit could be adopted. This was so in that large class of cases, where suit is brought to recover money paid by mistake or has been obtained by fraud. Here it is said the law implies a promise to repay the money, when it was well understood that the promise was a mere fiction, and in most cases without any foundation whatever in fact. The same practice was adopted where necessaries had been furnished an insane person or a neglected wife or child. In all these cases no true contract exists. They are, by many authors, termed quasi contracts, a term borrowed from the civil law. In all these cases no more is meant than that the law imposed a civil obligation on the defendant to restore money so obtained, or to compensate one who has furnished necessaries to his wife or child, where he has neglected his duty to provide for them, or, by reason of mental infirmity is unable to obtain them for himself.”

In the case at bar the money was paid by the auditor and treasurer of Cuyahoga County to the Village of Mayfield Heights under a mandatory order of the Probate Court. When the village authorities received the money they committed no wrong. .They had a right to rely upon the validity of the order and to apply it to village uses in accordance with the provisions of the General Code.

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188 N.E. 758, 46 Ohio App. 349, 15 Ohio Law. Abs. 664, 1933 Ohio App. LEXIS 373, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayfield-heights-v-gates-mills-ohioctapp-1933.