McGrath v. Cowen

11 Ohio C.C. 441
CourtOhio Circuit Courts
DecidedJanuary 15, 1896
StatusPublished

This text of 11 Ohio C.C. 441 (McGrath v. Cowen) is published on Counsel Stack Legal Research, covering Ohio Circuit Courts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McGrath v. Cowen, 11 Ohio C.C. 441 (Ohio Super. Ct. 1896).

Opinion

Swimg, J.

This was an action by a partner, McGrath, to wind up the business of the firm of Cowen & McGrath, a firm carrying on the boot and shoe business in the city of Cincinnati.

The controversy in litigation here is as to the validity of certain chattel mortgages.

The material facts in brief are, on May 20, 1893, and for a period of six years hitherto, the firm of Cowen & Mc-Grath were wholly insolvent. On that day McGrath executed four certain chattel mortgages on the property of the [442]*442firm for an amount equal to the firm’s assets. There were numerous other creditors unsecured. At this time none of the debts secured were due, and the mortgages were executed without solicitation or knowledge on the part of the mortgagees. The mortgages secured valid debts. Mrs. Cowen, the other member of the firm, was not consulted by McGrath as to the giving of these mortgages, although she was present in the store all of said day. For some time previous to said day, McGrath had been endeavoring to induce Mrs. Cowen to make an assignment of the firm’s assets, but she had persistently refused to do so. On said day, and before delivering the mortgages,bnt after their execution, McGrath had prepared the petition filed in this case, and together with his attorney and the attorney of Mrs. Cowen, who had been attending to her business in other matters, but who in this matter acted'without her knowledge or consent, agreed upon the appointment of a receiver,and who it should be. McGrath .expected that the giving of the mortgage would put an end to the running of the business. The mortgages were delivered on the following Monday morning, the 22nd day of May, and afterwards, on the same morning, this petition was filed and a receiver appointed, and when Mrs. Cowen c’ame to the store on said morning, she found the store closed and in charge of the receiver, and then for the first time she was informed as to what had taken place.

Our conclusion from these facts is: That McGrath having failed to induce Mrs. Cowen to join with him in making an assignment of the firm’s assets, executed these mortgages for the purpose of putting an end to the business, and that he intentionally and purposely concealed from her his .acts in'order that he might carry out this purpose.

The general rule as to the rights and duties of partners is thus stated by Parsons, on Partnership commencing at sec. 108:

[443]*443“The right of every partner to sell, assign or transfer, any part or the whole of the partnership property, in the way of the regular business of the partnership, is absolute and unquestioned. There is an exception to this rule in reference to the real estate of a partnership, but none as to the personal property. Suppose a partnership delt in buying and selling cotton, and all their stock consisted in five hundred bales stored in New York; there is no more doubt that either one of the partners might sell, and give good title to the whole, than that he could do so with a single bale. This, however, must be done in the regular course of the business of the firm; for outside of this he has no such power. If he does this in fraud of the other partners, that is, if he sells the whole, or any part, intending to run off with the proceeds, and does run off with them, this has no effect on the title of the purchaser, unless he has some knowledge of the fraud.
“If, however, a partner undertakes not to sell the goods or property of the partnership, but to assign them, by way of pledge or mortgage, to secure the debts of the firm, or in any unusual way, he has not necessarily any power to do this. Neither do we consider it certain that he has no power to do it. On the one hand, such a transaction seldom or never belongs to the regular business of a firm. If it does, of course he has this power. If ,it do is not, it may still be so far connected with, or so naturally arise out of or promote, their regular business, that if the transaction be an honest one, without bad faith on the part of any party, we should say it was a valid transaction, which the law would enforce. Perhaps a consideration of the authorities and of the reason of the case would lead to this difference between the selling ánd the assigning in pledge of partnership property by one partner. If the sale take place in the course of business, it would bind the other partners, as we have seen, though fraudulent as to them; but an asssignment in pledge or mortgage, not being in the way of business, would bind the other partners if it were done in good faith for the advantage of the firm, and was reasonable in itself, but not otherwise.
“One partner may, in good faith, ássign a part of the property to pay or secure an existing debt, or a debt to be [444]*444contracted. (There is some doubt, however, whether he has power to assign the whole property in trust for all the creditors. His power to transfer firm property generally is within the scope of the firm business, since the object of the business is to dispose of such property. But the assignment of all the property in trust for creditors is necessarily outside the scope of the business, since it puts an end to the business. The better opinion therefore seems to ’ be that in the ordinary case one partner has no power to assign all the assets in trust for creditors without the consent of the ether partners. But if the other partners are absent, and can not become at to be consulted, one partner who is thus left in charge of the business may in an emergency make a general assignment.)”

Lindley on Partnership, 1 Yol., p. *126, etseq., says:

‘‘It will be observed that what is necessary to carry on the partnership business in the ordinary way, is made the test of authority where no actual authority or ratification can be proved. This is conformable to the most recent and carefully considered decisions; but by adopting it,the liability of a firm fer the acts of its co-partners is not so extensive as non-lawyers sometimes imagine. The act of one partner, to bind the firm, must be necessary for the carrying on of its business; if all that can be said of it was that it was convenient, or that it facilitated the transaction of the business of the firm, that is not sufficient in the absence of evidence of sanction by the other partners. Nor, it seems, will necessity itself be sufficient if it be an extraordinary necessity. What is necessary for carrying on the business of the firm under ordinary circumstances and in the usual way is the test; and therefore, in a case where the nature of the business was one in which there was no necessity to borrow money to carry it on under ordinary circumstances and in the ordinary manner, the court held the firm not liable for money borrowed by its agent under extraordinary circumstances, although money was absolutely requisite to save the property of the firm from ruin. This case is an authority for saying that a power to do what is usual, does not nclude a power to be what is unusual, however urgent; and although, in the case referred to, the money was [445]*445not borrowed by a partner, but by a person who was only an agent of the firm, the decision would, it is apprehended, have been the same if he had been a partner. For notwithstanding the fact that every partner is to a certain extent a principal as well as an agent, the liability of his co-partners for his acts can only be established on the ground of agency.

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Bluebook (online)
11 Ohio C.C. 441, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcgrath-v-cowen-ohiocirct-1896.