Meisse v. Loren

4 Ohio N.P. 100, 6 Ohio Dec. 258, 1897 Ohio Misc. LEXIS 134

This text of 4 Ohio N.P. 100 (Meisse v. Loren) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Meisse v. Loren, 4 Ohio N.P. 100, 6 Ohio Dec. 258, 1897 Ohio Misc. LEXIS 134 (Ohio Super. Ct. 1897).

Opinion

Duncan, J.

This is an action brought by Meisse and others against James M. Loren and oéhers, who were officers and directors of the Fifth Avenue Savings Bank.

The plaintiff in this petition represents creditors and stockholders. It is an action brought on behalf of the creditors and stockholders of the bank against the officers and directors of the bank, charging them with misfeasance in office; charging that, on account of their negligence in attending to the business entrusted to them that the assets of tne bank depreciated to such an extent that it became insolvent,and that they are-the losers,and they are asking here for an accounting; so that their claims for damages may be paid.

To this petition a great many motions have been filed, and I have-gone over them all and examined them as carefully as I could under the-circumstances, and I find that a great many of them are frivolous. A great many of the motions are to strike out certain parts of the petition, and also to make definite and certain.

I find that the most important motion is the second one, and that motion is this: Said defendants further move the court to require the-plaintiff to separately state and number the alleged causes of action in such amended petition.

The question arises now, as to whether or not there is more than one-cause of action stated in this petition, and this depends on the question as to whether the directors and officers of a bank are trustees for the depositors and stockholders, and whether the},T can be called upon to account in a court of equity for misfeasance in the management of the-business of the bank.

[101]*101There is a distinction between banking corporations and other corporations for profit. In the one, a party deposits his money, most frequently without any reward, simply for the purpose of safe keeping, relying implicitly upon the business management and integrity of the directors of the bank, without any hope cf reward from it. There is considerable conflict in the decisions on this question, as to w'hether the directors of a corporation are trustees. The conflict is not so great in the ■decisions relating to banking corporations as in those relating to other corporations. Much of the trouble grows out of what is called the American and English doctrines, the former holding that the directors of corporations are trustees, and the latter that they are not.

It is a favorite dictum of the American courts that the capital stock and other property of a corporation is to be deemed a trust fund for the payment of the debts of the corporation, so that the creditors have a lien •or right of priority of payment on it in preference to any of the stockholders of the corporation. Thompson, Liability of Stockholders, section 10; 8 Mason. 308.

The decision in the 3rd Mason was rendered by Justice Story m 1824, in the Circuit Court of the United States, in Maine. The suit was by ■creditors against the stockholders of a bank for misappropriating the funds of the bank, to-wit: appirpriating it to themselves without paying the debts. It was held by Justice Story that the capital stock was a trust fund for the payment of the bank notes, and might be followed into the hands of the stockholders; that a bill in equity might be maintained by some of the holders of the bank notes against some of the stockholders, the impossibility of bringing all parties before the court being sufficient to dispense with the rule of making all parties in interest parties. * * * The bill holders and other creditors have the first lien on the capital stock, ■and the stockholders have no rights until all the other creditors are satisfied. * * * The doctrine of following trust funds into the hands cf any persons who are not innocent purchasers and do not otherwise possess ■superior equities has been long established.

Thompson on Corporations, section 4150, says the capital stock of a corporation is a trust fund for its creditors. He says this doctrine originated in this country ivith Justice Story, 3 Mason, 308. He says it is ■contrary to English doctrine, but that the American courts have adopted it.

The capital stock of a corporation contributed or agreed to be contributed by its stockholders, is in equity and as to creditors deemed a •trust fund, charged with the payment of the debts of the corporation, and must be treated as such by the corporation. Beach on Private Corporations, section 113; 91 U. S., 60; 7 Bevan, 1176; 25 Alabama R., 566-611-612.

The Supreme Court of this state 46 O. S. 493, recognizes this doctrine. ■Judge Williams, in rendering the opinion of the court, cites a great many of the leading cases with approval. Counsel representing these motions have cited 50 Ohio St., 151; 48 Ohio St., 66, and 47 Ohio St., 503.

The decisions in none of these cases are in conflict with that announced in 46 Ohio St., 493

Judge Williams wrote the opinions in the 50 and 48 Ohio St., and he ■certainly did not intend to, nor has he, destroyed the decision in the 46th Ohio St.

Judge Williams recognizeds that there is a conflict of authorities on the question as to whether the capital stock and assets of a corporation are a trust fund for the benefit of its creditors. After citing and commenting on a number of the leading cases, citing also the 3rd Mason, 311, which has been criticized by some authors, Judge Williams, uses this language: ■ “Since the case of Wood v. Dummer, 3 Mason, 311, where Mr. Justice Story is said to have first formulated the doctrinee, it has •been generally accepted, and is sustained by the highest authority.”

[102]*102Judge Williams concludes by saying: “Without extending the discussion, we are of opinion that where a corporation for profit, organized under the laws of.this state, becomes insolvent and ceases to carry on its business or further pursue the purposes of its creation, the corporate-property constitutes a trust fund for the equal benefit of the corporate-creditors in proportion to the amount of their respcetive claims.”

Mr. Beach, in his work on Private Corporations, section 116, uses this language: . “This is an American doctrine, being first annunciated by Mr. Justice Story, and since his day has been repeatedly expounded and firmly established in the jurisprudence of the American states,” citing a long list of authorities.

If the assets are a trust fund, then the directors, officers or any other persons into whose hands any of the fund has passed, except bona fide purchasers for value, may be called upon to account in a court of chancery, either by the creditors or the stockholders, or by both.

The managers of a savings bank stand in the relationship of trustees-to the depositors, so that the statute of limitations will not be a bar against a charge of mismanagement on their part.

Although such managers are unpaid, they are to be held liable for the want of ordinary care and diligence in the management of the affairs of the institution.

A long and systematic violation of the directions of the charter by the president and committeemen is prima facie presumption that such course-of misconduct was known to the managers, and the latter cannot demur to the bill on the ground that such misconduct is not traced to them. 40 N. J. Eq., 189.

The court in this case holds that there is a direct trust between the depositors and managers.

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Bluebook (online)
4 Ohio N.P. 100, 6 Ohio Dec. 258, 1897 Ohio Misc. LEXIS 134, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meisse-v-loren-ohctcomplfrankl-1897.