McLean v. Jephson

26 Abb. N. Cas. 40
CourtNew York Supreme Court
DecidedNovember 15, 1890
StatusPublished
Cited by1 cases

This text of 26 Abb. N. Cas. 40 (McLean v. Jephson) is published on Counsel Stack Legal Research, covering New York Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McLean v. Jephson, 26 Abb. N. Cas. 40 (N.Y. Super. Ct. 1890).

Opinion

Ingraham, J.

By section 3333 of the Code, an action is defined to be, “ An ordinary prosecution in a court of justice by a party against another party, for the enforcement or protection of a right, the redress or prevention of a wrong or the punishment of a public offence,” and by section 3334 of the Code it is provided," That every [43]*43other prosecution by a party for either of the purposes specified in the last section is a special proceeding.”

By section 416 it is provided that the civil action is commenced by the service of a summons.

This proceeding not having been commenced by the service of a summons, is not an action. It is however a prosecution in a court of justice by a party against another party for the enforcement of a right and is a special proceeding within section 3334 of the Code above cited.

Section 3240 provides that costs in a special proceeding may be awarded at the rate allowed for similar services in an action brought in the supreme court.

The court of appeals in this case having awarded to the successful party costs in all courts, it would appear that he is entitled to costs at the rate allowed for similar services in an action.

The provisions by which the court has power to award motion costs do not apply. Such costs are allowed under subdivision 3 of section 3251, which provides that upon any motion specified in section 3236, a sum to be fixed by the judge or court not' exceeding $10 besides necessary disbursements for printing and Referee’s fees, may be awarded. Section 3236 refers to costs upon a motion in an action.

In this case there was no action but a special proceeding, the order that was appealed from and which was reversed was a final order requiring the defendant to pay a sum of money.

It is true that the order committed the defendant as for a contempt in case he refused to pay, but the proceeding was not a motion in an action to punish for a contempt committed by refusal to obey an order in the action.

I think therefore that the taxation of the clerk must be set aside and the clerk directed to tax the costs as in an. action.

[44]*44The clerk was right in refusing to tax as a disbursement the fees of the chamberlain on deposit of the sum as security to stay proceedings on appeal. That was not a disbursement in the proceeding.

Motion granted as indicated with $10 costs of this motion.

Note on the Distinction between Actions and Special Proceedings.

The original distinction between actions and special proceedings is very well understood. The Code says, that an action is an “ ordinary prosecution,” etc., but “ ordinary ” needs definition even more than action. It means that form of prosecution where the claimant has a right to issue summons to answer a complaint stating the facts constituting the cause of action, and defendant has a right to take issue or set up his facts in defense or counterclaim, and either party may require a trial and a judgment, enforcible by execution ; as distinguished from those forms where the statute or the court prescribes other means of bringing in the defendant, or presenting the facts and formulating the decision and its enforcement.

Practically the only difficulty in the distinction is introduced by our complex statutes which have half obliterated the lines between them, by transformations from one category into another and back again. Even this would be of little importance, were it not that there are some very substantial differences between our rights in prosecuting an action, and our rights in prosecuting a special proceeding. The regulations differ more or less in regard to the service of some papers, the subjects of motions and orders, subpoenas, depositions, discovery of books and papers, amendment, abatement and continuance, and in some cases as to appeal and costs. Hence, the following suggestion of the points of departure may be useful.

The ordinary proceedings in an action sometimes branch out into a special proceeding, and in pursuing that branch the practitioner must not forget that he has crossed the line of demarcation.

On the other hand there are a number of special proceedings which at one stage or another are, so to speak, transmuted into actions, or subjected to the regulations applicable to actions, by reason of special provisions of statutes which, with the innocent intention of simplifying the practice, declare sometimes in one form and sometimes in [45]*45another, that a special proceeding shall be from such a point, or in such a respect subject to the provisions regulating actions.

The following references to the principal contrasts will serve as a convenient starting point for investigating the practical limits of the distinction in reference to all important matters.

There are some other special provisions peculiar to particular proceedings, which it would only confuse to notice here, the present object being to draw the general distinction, in the light of which to read special statutory provisions as to any particular proceeding, and decisions in the practice in any particular proceeding.

Notes oti statutes and cases.

Abatement and continuance in case of actions is regulated by Code Civ. Pro. §755-765.

Special proceedings are not within these provisions (Matter of Palmer, 43 Hun, 572 ; Matter of Roberts, 53 Id. 338 ; Matter of Barney, 53 Id. 480; compare People ex rel. Fairchild v. Coms. of Brooklyn, 105 N. Y. 674),—not even when in the surrogate’s court, (Herbert v. Stevenson, 3 Dem. 236, s. c., 1 How. Pr. N. S. 64).

But a special proceeding by or against an officer, receiver or other trustee, does not abate on his death or removal, the rule on that point being the same as in an action, § 766.

Amendments in actions are regulated by Code Civ. Pro. § 721-728.

Amendments in special proceedings in the four main courts or classes of court, (supreme, superior, city, county, and New York city), are regulated by the same provisions (§ 3347, subd. 6; and § 1997 as to State writs and amendments in special proceedings in all other courts of record, a term which now includes surrogates courts), are regulated by the same provisions, (id. and § 2538) ; (condemnation proceedings § 3368). § 723 as to amending, as to parties and .pleadings is applicable to all courts, § 3347, subd. 6.

For the purpose of appeal to general term an order made in a summary application after judgment in an action, is deemed to have been made in the action (§ 1347).

The rules as to costs in actions, and security for costs are - applied approximately in special proceedings, (§§ 3240, 3379).

Depositions de bene esse, and depositions taken without the State and examination of parties before trial, are allowed only in actions by §§ 879, etc., § 887, etc., and the statute is extended to special proceedings in surrogate’s courts, (§ 2538, contra Estate of McCoskry, 5 Denn. 256, s. c., 10 Civ. Pro. R. 178).

[46]*46Otherwise they are not allowable in special proceedings (Matter of an attorney, 83 N. Y.

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Bluebook (online)
26 Abb. N. Cas. 40, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mclean-v-jephson-nysupct-1890.