Metcalf v. Cook

2 R.I. 355
CourtSupreme Court of Rhode Island
DecidedSeptember 6, 1852
StatusPublished

This text of 2 R.I. 355 (Metcalf v. Cook) is published on Counsel Stack Legal Research, covering Supreme Court of Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Metcalf v. Cook, 2 R.I. 355 (R.I. 1852).

Opinion

Haile, J.

delivered the opinion of the Court.

The respondents by their demurrer admit the truth of such allegations in the complainant’s bill as are well pleaded. The right of the complainant therefore to the exercise of the equitable jurisdiction of this Court must depend upon the allegations in said bill, the legal construction of the said will of Elisha Waterman, the trusts thereby created; and such rules of equity applicable to said trusts as may be deemed consistent with the established laws and policy of this State relative to the legal rights and liabilities of married women, and their power and control over their separate property and estate.

Such rights, liabilities, power and control, are well *363 established and defined in this State, by positive statute, and by the rules of the common law. And a feme covert here, is not deemed in relation to her contracts, as in some cases in England, a feme sole. But her right and power to bind herself or her separate property must depend in each ease, upon our statutes, the rules of the common law, or upon some legal instrument creating such right and power.

This guaranty of said promissory note by said Abigail Whipple, could not make her personally liable either at law or in equity, because she, being at the time a feme covert, had no power'to give such guaranty.

In considering therefore the claim of the complainant upon the separate property and estate of said Abigail, this note standing alone cannot be deemed legal evidence th support this claim ; but in order to sustain this claim, it must be shown that by the rules of equity she had power under the said will of her father and the trusts thereby created so to pledge her separate property.

The rules of the English chancery in regard to the power of a feme covert over her separate estate, as laid down in their former and later decisions, are very conflicting, as-will be seen by reference to the cases cited at the argument of this cause. And these decisions being so conflicting and unsatisfactory, and opposed to the policy of our laws and institutions, we deem them an unsafe guide as precedent or authority for the decision of this case ; and especially as these decisions are almost directly opposed to the decisions on this subject of the highest and most respectable judicial tribunals of several of our sister States, the policy of whose laws and the practice under them more nearly conform to our own.

*364 For while by the English decisions it is held that a feme covert, in respect to her separate estate, is to be regarded as a feme sole, with all the powers which belong to that character, and that her note or bond or other obligation will bind her estate, the rale adopted in most of the American Courts is, that a married woman has no power in relation to her estate, but such as has been expressly given to her, and that her note or bond will not charge her separate estate, except where a provision for that purpose is contained in the instrument creating the separate estate. (65 Law Library 370.)

The lead in departing from the Euglish and establishing the American doctrine was taken by the Court of Appeals of South Carolina, in the case of Ewing v. Smith, in 1811; and has been since affirmed by repeated decisions ; and, was finally authoritatively settled by that Court, in Reid v. Lamar, (1 Strobhart’s Equity, 27, 37,) in 1845, in which latter case, it was decided that an estate settled to the separate use of a feme covert, to be at her “ full and free disposal,” was yet not chargeable by a note given by her and her husband. And this Court held it to be the settled law of that State, that where property is given or settled to the separate use of a married woman, she has no power to charge, encumber or dispose of it, unless in so far as power to do so has been expressly conferred on her by the instrument creating her estate; which power must be strictly pursued.”

This decision is in conflict with many English cases, in which it has been held that she is a feme sole, with respect to her separate prpperty, and may charge or dispose of it as she pleases, unless in so far as she is expressly restricted by the instrument.

Chancellor Kent, in the case of the Episcopal Church *365 v. Jaques, (3 Johnson’s Chancery Rep. 78,) after a careful review of the English authorities, in a clear and forcible argument, repudiates the English doctrine, and supports the doctrine of the South Carolina Courts, as the true rule in equity based upon wise policy and practical common sense.

This decision of Chancellor Kent, however, was overruled by the common law judges in the Court of Errors. But the wisdom of the Legislature of New York has corrected this last error, by their revised statutes ; and the decisions of the Courts in that State under these statutes, have adopted the decision of Chancellor Kent, to a great extent, as the true rule in equity on this subject.

In Pennsylvania, Tennessee, Mississippi and Virginia, the rule of the South Carolina cases and the views of Chancellor Kent have been adopted. And, in the case of Williamson v. Beckham, (8 Leigh, 20, 27,) it is said by Tucker, J. “ I am of opinion that a ferns covert, holding separate property in real estate by deed or will, prescribing a peculiar mode of disposition, cannot dispose of it in any other mode, although the deed or will does not negative such other mode expressly.”

Another rule equally well established in law and equity should be applied in construing the said will of Elisha Waterman ; that the intention of the testator should be the guide to govern in this construction.

Now let us apply these rules to the instrument in question as the proper test of the complainant’s claim set up in his bill.

The testator does not give and devise directly to his said daughter Abigail Whipple, the personal and real estate intended by him as a bounty to her; but gives and devises it to Richard Carrique in trqst, for said trustee *366 “ to (alee possession of and manage ; and, also, to collect and receive the rents and profits of said real estate as well as the interest and income of said personal estate, and as often as once in every year to pay over to his said daughter Abigail Whipple all such rents, profits, interest and income to and for her sole, separate, exclusive use and benefit during the term of her natural life.”

The testator in said \yill empowers his said daughter to give, devise and bequeath said real and personal estate by her last will and testament with like legal effect as might be done by a sole and unmarried woman.

The testator also authorizes his said trustee to sell and convey any part of said trust estate, the said Abigail joining in the conveyance in token of her consent ; but the said trustee is required by the will to invest the proceeds of such sale for the same purposes and trusts.

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Bluebook (online)
2 R.I. 355, Counsel Stack Legal Research, https://law.counselstack.com/opinion/metcalf-v-cook-ri-1852.