McRae v. McRae

1 Balt. C. Rep. 353
CourtBaltimore City Circuit Court
DecidedApril 6, 1893
StatusPublished

This text of 1 Balt. C. Rep. 353 (McRae v. McRae) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McRae v. McRae, 1 Balt. C. Rep. 353 (Md. Super. Ct. 1893).

Opinion

WICKES, J.

The original bill filed in this case prayed the enforcement of a contract entered into between the late Charles McRae, the husband of the plaintiff, and George P. McRae, his brother, one of the defendants. The bill recites that on the 20th day of April, 1888. George McRae leased to Charles, for a period of five years, a house and lot of ground in this city upon certain conditions and terms set forth in the lease, which said lease also contained the following covenant, to wit: That the said George would at any time during the lease “upon payment or tendering payment by the said Charles McRae,, his heirs or personal representatives, to the said George P. McRae, his heirs, personal representatives or assigns, of the sum of $10,000, and all rents, &c.”; “that the said George, his heirs, personal representatives or assigns, will execute and deliver to the said Charles McRae, his heir or personal representatives, a good and sufficient deed, in fee, of the lot of ground and premises hereinbefore described, &c.”

It is admitted in the answer that the lease was executed, and that Charles complied with all the terms on his part, and that a sum of money was tendered and a bill demanded, but that the defendant, George, is unable to convey, because his wife refuses to join in the deed.

The question is therefore presented, and strangely enough it seems to be of first impression in this State, what power, if any, a Court of Equity has to decree specific performance of such a contract, so far as the husband’s interest is involved, with pecuniary compensation for the dower interest of the wife.

We find a conflict of decisions elsewhere.

In Pennsylvania and New Jersey the current of authority is adverse to the power of a Court of Equity to give relief in such cases, but Pomroy in his treatise on Specific Performance, severely criticises the reasoning of the Pennsylvania cases, and strongly inclines to the doctrine of the New York and Massachusett’s decisions. In 14 Allen (Davis vs. Parker) 94, the defendant agreed to convey by a good and sufficient deed, &c. The defense was, inter alia, that the wife refused to release. Hoan, J., delivering the opinion of the Court said. “If defendant tendered the best deed in his power to make, it was not such a deed as his contract bound him to execute, nor such as the plaintiff was required to accept. If he was unable to procure a release of dower, he should have accompanied his tender of a deed, with an offer to deduct the value of the incumbrance from the purchase money. At the election of the plaintiff, there may be a decree for specific performance so far as it is in the defendant’s power pro tanto, and a proportionate reduction made from the purchase money for the part which cannot be specifically performed.”

In Bostwick vs. Beach, 103 N. Y. R. 414 (decided in 1886), the defense was the refusal of the widow to join in the deed made by the executors under a power of sale contained in the will. The Court held (Rapallo, J.) :

“If the purchaser should elect to carry out his purchase and take title to the laws subject, to that dower right, he would clearly be entitled to do so, and in that event would be entitled [354]*354to ail abatement from the contract price, equal to the gross cash value of the right of dower. If a seller of land is not able to' comply fully with the contract, either in respect of the quantity of land or the extent of the estate, the Court will, at the election of the buyer, decree specific performance of the contract, so far as the same can be performed, awarding compensation to the purchaser by way of abatement from the purchase money, for any deficiency in title, quantity of land, or other matters touching' the estate, the value of which are capable of being ascertained and thus compensated without doing injustice to either party,” and then cites with approval the Massachusetts case of Davis vs. Parker, above referred to. Continuing, the Court say, “The gross value of the dower right has been adjudged in such cases to be the measure of compensation to be allowed to the purchaser by way of abatement from the price.” See also 2 Beach. Mod. Eq. 628, and note. Indeed, it is difficult to understand why Courts of Equity should not deal with questions of this character, unless upon the theory of one of the cases that the true remedy was to commit for attempt, the husband who fails to obey the decree of the Court, which would of course give color to the doctrine of the Pennsylvania eases, that a decree of specific performance under such circumstances would coerce the wife into parting with her interest.

A clearer case for the application of the principle adopted in Davis vs. Parker and Bostwich vs. Beach can scarcely be conceived than the one in hand. It is manifest from the evidence that the defendant, George P. McRae, has made no effort at all to induce his wife to release her dower; on the contrary, her testimony shows that he never talked to her about signing a deed, and his bookkeeper, Myer, has testified that at the time the money was tendered for the property, the reason the defendant assigned for not selling was that the property “was worth more to him than was offered.”

I would not hesitate to enter a decree on this branch of . the case but for the amended bill and answer, which introduce another and different issue into the case.

At the taking of the testimony under the original bill, the plaintiff became apprised of facts which induced her to believe that the agreement or understanding between Charles and George McRae at the time the property in question was sold by the trustees appointed by the Circuit Court for that purpose, constituted the transaction substantially a loan from George to Charles, for which the deed from the trustees to George, although conveying upon its face a fee-simple estate, was in reality but a security for the payment of the purchase money $10,-000, at any time during the five years covered by the lease. An amended bill was therefore filed setting forth the newly discovered facts, as she under-' stood them, and praying for other and appropriate relief. The answer denied the agreement as set forth in the bill, and relied largely, as has the learned counsel in argument, upon the character of the deed from the trustees, as establishing the bona fide purchase by George of the estate sold by the trustees. But the question is not, of course, to be determined by the face of the deed, or even by what the trustees supposed, but by the agreement between the parties themselves.

At the time the agreement in question was entered into, the only persons present were Mr. Merryman, the counsel of both the parties at the time, Mr. Littig, one of the trustees, and George and Charles McRae. Charles having since died, George is incompetent to testify. Biggs vs. McCurley, Atlantic Reporter, Jan. 11. 1893, 466. We are reduced, therefore, to the testimony of Mr. Merryman and Mr. Littig as to what was the real understanding between the parties to the lease at the time the property was sold.

Mr. Merryman has testified that he was counsel for the trustees at the time the sale was made. That the property was knocked down to Charles, and reported in the name of George, because of an agreement between them, made at the time of the sale, and in the presence of himself and Mr. Littig. The agreement, he states, was that Charles should have the property whenever he paid the $10,000 to his brother, George. He further says that George was substituted for Charles in the purchase because of Charles’ [355]

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Bluebook (online)
1 Balt. C. Rep. 353, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcrae-v-mcrae-mdcirctctbalt-1893.