M'Haney v. Crabtree

22 Ky. 104
CourtCourt of Appeals of Kentucky
DecidedOctober 24, 1827
StatusPublished

This text of 22 Ky. 104 (M'Haney v. Crabtree) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
M'Haney v. Crabtree, 22 Ky. 104 (Ky. Ct. App. 1827).

Opinion

Chief Justice Bibb

delivered the Opinion of tho Court.

In an action at law on an injunction bond against the principal and surety, the latter attempted to defend himself by two special pleas, relying on an execution of fieri facias on the original judgment, the levy of it on the property of the principal, and an arrangement between the principal and the plaintiff, without the knowledge or assent of the surety, whereby the property of the principal was released from execution, and this ar[105]*105rangement is pleaded at law as a release. The pleas upon demurrer were adjudged insufficient.

Jurisdiction. Release of the surety by an agreement Avith the principal, whereby the risk of the surety is increased without his consent, is ground of defence in equity, not at lavr.

The principal question in the cause is, whether the defence was of a character to be insisted on at law as a release; or belonged exclusively to a court of equity.

The release of a surety, by an agreement with the principal for enlarging the time, or by other act which increases the risk of the surety without his assent, we take to be, of equitable jurisdiction. It most properly belongs to the jurisdiction of a court of equity. It is an equitable release, not a release pleadable at law. The doctrine is, that equity considers the surety as but a guarantee for the performance by the principal. Whether it appear by the obligation or not, that one is principal and the oth-security, does not seem to us to be the point which gives or denies to the courts of common law, the cognizance of the defence. Whether both appear on the face of the bond as principals, or one as principal, and the other as security, the obligation on both is for the performance of an act or duty, if that for which the obligation binds them be not done, the bond is broken, and so the letter of the bond is equally forcible againt principal und security. The treatment which the principal has received at the hands of the obligee, by postponement of the time for performance, or by losing a lien on the property of the principal, or by otherwise increasing the risk and responsibility of the surety, without his concurrence, of which the surety com-Elains, and shows as an excuse and discharge for imself seems properly referrable to the head of equity. The bond must have been broken, otherwise no suit can be maintained at law against principal or security. That the principal remains hound still by his obligation, is admitted by the very nature of the subject of which avc are treating. A release at law which discharges one obligor (who was bound fully and completely) and yet leaves the other bound, an excuse for non-performance by one which shall yet be no excuse for the other obligor, is [106]*106an anomoly in the courts of common law, and seems to belong to the jurisdiction of a court of equity.

Plea by the surety, in an action on an injunction bond, that after the dissolution of the injunc tion, an execution on the judgment at Jaw had been levied on the estate, and the plaintiff had released the property, is not sufficient — because but a part of the action is answered, and the surety’s remedy in such case is in equity.

There are excuses for non-performance known to the courts of common law; but these are not excuses to avoid a broken covenant, condition or undertaking, but excuses which prove that the covenant, condition or undertaking has not been broken by the party who pleads such excuse. The obligation in such case, has not been violated by the party pleading the excuse, and the whole obligation, condition or covenant is saved, and the action against principal and security is alike defeated. But an excuse which saves the security, but leaves the principal bound by the obligation, would seem most aptly addressed to a court which acts upon the conscience of all the parties concerned; which can divide, separate, distribute and enforce their respective duties to each other. This case itself furnishes an illustration. The pleas relied on, state that after an injunction dissolved, an execution issued on the original judgment, that the execution was levied on the property of the principal, and by direction of the creditor, the sheriff did forbear, and the execution was returned to the office. The plea does not pretend that the damages given on the dissolution of the injunction, and the costs also .given in chancery were included. These were after the original judgment, and by the plea not included in the exer cution so delayed. Yet these costs and damages come within tire condition of the injunction bond, and are expressly stated and demanded in this action. The delay of execution cannot, in equity, have released the -surety from these, because, as to these he is not injured by that delay; they could not have been levied under that execution. This delay and hin-derance may have, in equity, released the surety for so much as was included in the execution, but could not release him totally from liis liability on the injunction bond. A court of equity may relieve the surety pro tanto, and leave him liable for the residue. Thus the propriety of referring this question to a court of equity, which can so frame its decree as to divide and distribute the sums due from principal alone, and from principal and pure-[107]*107iy, rather than to a court of law which must sustain the plea to the whole action; or not at all, is manifest. But it also proves that the pleas so pleaded to the whole action for principal, interest and cost at law, and for damages and costs awarded in chance-re, were bad; for if the pleas were true, yet the facts did not amount to a discharge of the security from the whole action, and being pleaded in bar of the action, were bad.

Cases in the Supreme court, of sureties pleading releases by the indulgences to the principal, not allowed. Like plea in. New-York, allowed.

There are three cases which have come under our notice, where the release of the surety by the delay or negligence of the creditor in coercing the principal, were urged in suits at law. Two of these are in the Supreme Court of the United States; Kirkpatrick vs. the Unitd States, (9 Wheat 720,) United States vs. Vanzant (11 Wheat. 184,) and the people of New-York vs. Jansen, (7 John. 332.) In the two former the defence was overruled; but the question of the propriety of such defence in a court of common law was not considered with reference to the distinction between the jurisdiction of the courts of law, and the courts of equity; the defence set up in both of these cases was overruled in chief, and therefore such a question was not necessary to be considered. Besides in both of these cases the defence was against the United States on bonds of an officer, lor balance of accounts; and if the defences were available at all, the court might have admitted them at law, that there might not be a failure of justice; for it has not yet been decided by the Supreme Court of the United States, that a bill in equity will lie on behalf of an individual against the Government. The cases of .the United States against their debtors, might possibly allow an exception to the general rule of defences allowable at law, as between individuals.

In the case of The people vs. Jansen, the release of the surety by the default of the officers of the Government to proceed against the principal in due time, was adjudged, and adjudged to be pleadable at. law.

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Related

United States v. Vanzandt
24 U.S. 184 (Supreme Court, 1826)
People v. Jansen
7 Johns. 332 (New York Supreme Court, 1811)

Cite This Page — Counsel Stack

Bluebook (online)
22 Ky. 104, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mhaney-v-crabtree-kyctapp-1827.