Moore v. Cincinnati Mining Co.

25 Ohio N.P. (n.s.) 197, 1922 Ohio Misc. LEXIS 291

This text of 25 Ohio N.P. (n.s.) 197 (Moore v. Cincinnati Mining Co.) 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
Moore v. Cincinnati Mining Co., 25 Ohio N.P. (n.s.) 197, 1922 Ohio Misc. LEXIS 291 (Ohio Super. Ct. 1922).

Opinion

Rogers, J.

The action is to recover certain rents and royalties claimed to have accrued under á coal mining lease of certain described real estate with the appurtenances situate in Athens county, Ohio. The ease is submitted to the court without a jury on the pleadings and evidence consisting of an agreed statement of facts.

The pleadings and evidence in substance and effect are as follows: the lease was duly executed on December 31st, 1892, by one Dorcas Allison, then the owner of said premises, to the Athens Coal Company, a corporation of West Virginia, its successors and assigns, for a period of thirty years. The lessee as part of the consideration for said lease, for itself, its successors and assigns, covenanted with the lessor, her heirs and assigns, to pay a royalty of 7 cents per ton during said term for all lump coal mined, provided the sum equalled 75 tons, or more, on the average for each working day, payable on the [198]*19825th of each calendar month for the coal mined the preceding month; and providing further that if said coal mined did not equal 75 tons a day for every month, then to pay upon the amount of 75 tons at least for each working day per month.

After certain successive assignments of the leasehold estate were made, the Ludwig Coal Company, a corporation, became the owner of said leasehold. And. a dispute having arisen abount the rental of houses on the premises, a supplemental agreement of lease was duly executed on Febrcary 27th, 1907,' between the then successors in title of the lessor of said premises "and the Ludwig Coal Company whereby it agreed to pay rent at the rate of $2.50 per month for the houses on the premises not occupied by employees of said company, and said obligation was to be binding during the remainder of said lease.

. Thereafter, said leasehold was successively assigned by divers transfers by and through respective assignees thereof until March 26, 1918, when it was duly assigned to the defendant. Although the defendant accepted said assignment, and has without hindrance at all times since said assignment, had the. right of possession, it never in fact went into actual possession of the leased premises, nor operated the mines thereon either by itself or through others. However, defendant paid the rents and royalties maturing under the provisions of the lease up_ to- March, 1920. On February 9th, 1920, the defendant notified by letter the plaintiffs who had then and for some time theretofore become through divers transfers the owners of the estate in fee in revision from the original lessor, Dorcas Allison, of its desire to pay up the royalties and surrender said lease as of March 1st, 1920, advising the plaintiffs that the letter might be considered by them as formal notice of such surrender. No reply appears to have been made to said letter nor assent of any kind given to the surrender of said lease by the plaintiffs. The amount of the rents and royalties having accrued under said lease at the time of the suit are not in dispute; but, under the facts, the substance of which are above related, defendant denies any liability therefor.

The main, if not the only question, in the case is this:- Is [199]*199the defendant, as assignee of the lease through successive transfers from the original lessee, liable for the rents and royalties in question, although it has not been in actual possession of the leased premises, but at all times and without hindrance since the assignment has had the right of possession thereof? ■

The right of the plaintiffs to recover, if at all, is based, not upon, any privity of contract with plaintiffs, but upon privity of estate. Defendant by reason of successive assignments of the leasehold from the original lessee, supplemented by the later agreement of lease with one of the intermediate assignees, stepped into the shoes of the original lessee and intermediate assignees, and the privity of estate raises the liability, if at all, to pay such rents and royalties. The only question is as to when this privity of estate attaches so as to render the defendant, as assignee, liable for the rents and royalties expressly covenanted to be paid under the original lease - and later supplementary agreement.

There are two lines of authorities on this subject. According to one line of authority, the assignee does not become liable to the lessor or his successors in title until the former takes actual possession of the leasehold estate. This doctrine was first announced in England by Buller, J., in Eaton v. Jaques, Second Doug. 4, K. B. 455, wherein he declared, in substance, that mere nominal assignees with the naked right should not be liable, but only substantial assignees in the actual enjoyment of the estate should be liable. This doctrine, however, was subsequently repudiated in Williams v. Bosanquet, 1. Broad & B., 238. 263, wherein Dallas, C. J., in referring to Eaton v. Jaques, supra, said:

“It has been further said that there is no privity of estate because possession was not taken; * # * but it is not so; for there is privity of estate, if legal possession, that is, acceptance of the thing assigned by acceptance of the assignment, be equivalent to actual entry; which it is, if there be justness in the observations already made; * * * in the ease of actual acceptance; assignees would, of course, be liable, and they may accept without entry; the assignment is not compulsory on them to take; if they do not take, they will [200]*200not be liable notwithstanding the assignment; but if they elect to take, then it is their taking, but not singly by the assignment they become liable as assignees. To the case of Dale v. Westerdell (7 T. R. 312) and Stone v. Evans (Woodfall’s L. & T. c. 3 s. 15), it will be sufficient merely to refer, as showing the dis-' approbation which Lord Kenyon entertained and expressed of the decision in Eaton v. Jaques; and to this it is hardly necessary to add, what is well known, that it did not meet with the • approbation of the profession at large. Remaining, however, as an authority, though a single authority, when this present ease came before this court on demurrer, it was directed by the late' Chief Justice to be turned into a special verdict, that we might have it argued before all the judges, and collect their opinion on the point. This has accordingly been done; and we have authority to say, that in the opinion of a great majority, Eaton v. Jaques is not to be considered as having been rightly decided.”

Other cases in England might be cited, discrediting the doctrine in Eaton v. Jaques, supra, and may be found in the references hereinafter made.

Some authorities in this country have followed the ruling of Eaton v. Jaquees. As for example, Damainville v. Mann, 32 N. Y. 197, announced a like doctrine, and the same is true of other eases in that state. Still other eases, however, are not in' accord with the principle announced in 32 N. Y. and the New' York courts refuse to follow it. In this connection may be mentioned Tate v. Neary, 52 App. Div. 78, 65 N. Y. S. 40. Likewise in Vermont some of the cases sustained the doctrine in Eaton v. Jaques, while .others repudiated it. This question is exhaustively treated in a note to Kanawaha-Juley Coal & Co. Co. v. Sharp, 52 L. R. A., at page 981, wher.e the authorities áre collated. See also note to the same case in Ann. Case 1916 E. 801.

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Related

Damainville v. . Mann
32 N.Y. 197 (New York Court of Appeals, 1865)
Tate v. Neary
52 A.D. 78 (Appellate Division of the Supreme Court of New York, 1900)

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25 Ohio N.P. (n.s.) 197, 1922 Ohio Misc. LEXIS 291, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moore-v-cincinnati-mining-co-ohctcomplfrankl-1922.