People ex rel. Neftaniel v. Order of American Star

21 Jones & S. 66
CourtThe Superior Court of New York City
DecidedFebruary 15, 1886
StatusPublished

This text of 21 Jones & S. 66 (People ex rel. Neftaniel v. Order of American Star) is published on Counsel Stack Legal Research, covering The Superior Court of New York City primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People ex rel. Neftaniel v. Order of American Star, 21 Jones & S. 66 (N.Y. Super. Ct. 1886).

Opinion

Freedman, J.

The questions raised upon the call of this case in its order upon the calendar for trial called for a careful examination of the present provisions of law relative to the proper mode of proceeding upon a return to an alternative writ of mandamus.

I have made such an examination since the adjournment of the case last week, and the following is the result.

At the common law, the relator was not permitted to traverse the return, notwithstanding that it might be false in fact; but the remedy was either by an action on the case for a false return, or, if the matter concerned the public, by indictment against the person making the return (2 Johns. Cas. 2 ed. 217).

Subsequently it was provided by statute that whenever a return shall be made to any writ of mandamus, the party prosecuting such writ may demur or plead to all or [68]*68any of, the material facts contained in the return, to which the person making such return shall reply, take issue or demur, and the like proceedings shall thereupon be had, as might have been had, if the person prosecuting such writ had brought his action on the case for a false return (2 B. S. 586, § 55 ; 10 Wend. 32 ; 3 How. 380). A similar statutory provision also existed previous to the Revised Statutes (1 R. L. 107, § 2). But although the statute permitted the relator to demur or to plead to the return, it was held that he could not do both (1 Wend. 38).

In case of a demurrer, the practice under the Revised Statutes was stated by Sutherland, J., as follows: “ Although these statutes contemplate formal written pleadings in the ordinary mode of conducting suits, the practice of the court is virtually to allow pleadings ore tenus ; that is, the relator is permitted to discuss the return, and to ask for a peremptory mandamus, and whilst he does not put in a formal demurrer, the case is considered as embraced in the description of non-enumerated business, and is heard as such ; but if a formal demurrer is-interposed, it becomes enumerated business, and can be heard only at the stated terms. It is optional with a relator whether it shall be considered enumerated or unenumerated business unless the court specially direct formal pleadings to be interposed ” (6 Wend. 559).

But if the relator took issue on the return by pleading thereto, he could not afterwards question its legal sufficiency (26 N. Y. 316), and the issue of fact had to go down to the circuit- for trial (7 Wend. 475). The case was then prepared and brought on for trial, the same as in personal actions. The relator held the affirmative of the issue, and the return was taken as true until it was falsified upon the trial (24 Barb. 341).

The foregoing constitutes an outline of the practice as it prevailed under the Revised Statutes, sufficient for present purposes.

In this practice the provisions of the Code of Civil [69]*69Procedure, which are mostly new, have made sweeping changes. Section 2080 abolishes oral pleadings, and allows no pleadings except such as are prescribed in sections 2067-2079. The only pleadings expressly prescribed in these sections consist of the writ—which is to fulfill the function of a complaint, the return—which is to fulfill the function of an answer, and a demurrer—which may be either a demurrer by the defendant to the writ (§ 2076), or a demurrer by the relator to the return (§ 2078).

The facts constituting the grievance complained of in the writ are to be stated in the manner in which a cause of action is to be stated in a complaint, and two or more of such grievances may be joined as so many causes of action. The person upon whom the writ is served, may demur or make return to the writ; or he may file a demurrer to a complete statement of facts contained in the writ, as constituting a separate grievance, and make a return to the remainder of the writ (§ 2076).

So the provisions of chapter sixth of the Code, relating to the form and contents of an answer, containing denials and allegations of new matter, except those provisions which relate to the verification of an answer, and to a counter-claim contained therein, are made applicable to a return to an alternative writ of mandamus, showing cause against obeying the command of the writ, and, for the purpose of the application, each complete statement of facts, assigning a cause why the command of the writ ought not to be obeyed, is regarded as a separate defense, and must be separately stated and numbered (§ 2077).

Section 2079 then provides that an issue of fact arises upon a denial, contained in the return, of a material allegation of the writ, or upon a material allegation of new matter, contained in a return, unless a demurrer thereto is taken; and that, where the relator demurs to a complete statement of facts, separately assigned as cause for disobeying the command of the writ, an issue of fact arises, with respect to the remainder of the return.

And finally, section 2082 provides as follows : “ Except [70]*70as otherwise expressly prescribed in the act, the proceedings, after issue is joined, upon the facts or upon the law, are, in all respects, the same as in an action, and each provision of this act, relating to the proceedings in an action, applies thereto. For the purpose of the application, the writ, the return, and the demurrer are deemed to be pleadings in an action. ...”

It thus clearly appears, that not only is there no provision made for a plea or reply to a return, but also that such plea or reply is no longer necessary under section 2079, and that by section 2080, it is even prohibited. Unless a demurrer is taken to the return, for insufficiency in law Upon the face thereof, as provided by section 2078, an issue of fact is created by the return itself under section 2079. In a note to the section last mentioned, Mr. Throop expressly says that the effect of the section is to dispense with a reply. The return is, therefore, to be treated in all respects like the answer to a complaint under section 964. But no answer requires a reply unless it contains a counter-claim (§ 514).

The consequence of all this is that the old rule that the relator, unless he demurred to the return, was bound to plead to it, and that, unless he so pleaded, the return was to be taken at the trial as true, has been completely abrogated.

In the case at bar the alternative writ shows that it was issued on the relation of Schaier Heftaniel, as President of the Edward Lasker Lodge No. 6, order of the American Star.

It recites, and the return does not deny, that said Edward Lasker Lodge Ho. 6, was duly created and instituted by the defendant as a subordinate lodge of the Order of the American Star, and that thereby it, and its members, became, pursuant to the charter granted to it and them by the defendant, entitled to certain rights, privileges and beriefits, and to an interest and share in the corporate property of the defendant.

The grievance complained of is then set forth by the [71]

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Bluebook (online)
21 Jones & S. 66, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-ex-rel-neftaniel-v-order-of-american-star-nysuperctnyc-1886.