Phipps v. Worthington

1 Balt. C. Rep. 17
CourtBaltimore City Circuit Court
DecidedDecember 22, 1888
StatusPublished

This text of 1 Balt. C. Rep. 17 (Phipps v. Worthington) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Phipps v. Worthington, 1 Balt. C. Rep. 17 (Md. Super. Ct. 1888).

Opinion

DENNIS, J.

In 1882, Patrick Kennedy and Arreanah Kennedy, his wife, executed to one John Delcher a lease of a certain lot of ground lying in what is now Baltimore City, for the term of ninety-nine years, subject to the annual rent of forty shillings, with the usual covenants by the lessors for renewal from time to time forever.

The amended bill in the case was filed in 1885, by parties claiming the leasehold interest by virtue of certain mesne conveyances from Delcher the lessee, against a number of named defendants, who the bill alleges claim an interest in various ways to a part of the reversion, and also against the unknown heirs of certain other parties who, it is alleged, likewise claim an interest in other parts of the reversion; and the prayer for relief asks:

1st. That the Court take jurisdiction of the case, and construe the several indentures, marriage settlements, acts of attainder, escheat warrants, &c., which are more fully set out in the bill, and under which the several [18]*18defendants claim, so as to ascertain who are in fact the parties entitled to the reversion.

2nd. That it will then decree against the parties so ascertained to be entitled to the reversion, that they shall execute a renewal of the original lease in accordance with its covenants.

3rd. That an order of publication may issue against certain of the defendants who are non-residents, and also against the unknown heirs of certain other parties; and

4th. As auxiliary to the relief already prayed, an injunction is asked to restrain the prosecution of an action of ejectment already instituted in the Court of Common Pleas by certain of the defendants, until the issues involved in the present case are disposed of.

To this bill a demurrer has been filed, and is sought to be sustained mainly upon three grounds:

1st. Because in a suit to enforce the specific performance of a contract (in this case, the covenant for the renewal of the lease), the bill must show upon its face with certainty the proper parties defendant, and no others; so that the Court may see that those proceeded against are legally bound, and are competent to do that which it is asked to compel them to do;

2nd. Because a suit to enforce the specific performance of such a contract is a proceeding in personam, and hence no decree can bind non-residents who are made parties only by publication.

3rd. Because of laches, on account of the delay in instituting the proceedings for renewal.

Before considering these grounds of demurrer, there is another objection to the bill, which must be adverted to. Ch. 154 of the Acts of 1886, provides that whenever the lessee named in a lease containing a covenant for perpetual renewal “shall have retained uninterrupted possession of the demised premises for twelve months after the expiration of such lease hereafter expiring, or for tioelve months after this Aet talces effect where any such lease has heretofore expired, it shall be conclusively presumed, with reference to said demised premises, where possession shall have been retained as aforesaid, and in favor of the lessee and those claiming under him, that a new lease of said demised premises was executed prior to the expiration of said lease, by the lessor therein named or those rightfully claiming under them, to the lessees, for such additional term, and upon the conditions, &c., contained in the original lease.” This Act went into effect on the 1st day of April, 1886.

I think it very clear, from its terms, that the Act has no application to those of the defendants, who had already, prior to its passage, brought their action of ejectment for the recovery of the demised premises; but all those defendants who had not prior to its passage, or within twelve months thereafter, brought their actions, are directly within its terms; and if the Act is a valid exercise of legislative power, so much of the bill as relates to this class of defendants is bad, because, in seeking a renewal of the lease, it simply asks the Court to compel the defendants to do that which by the terms of the Act, the Court is bound to conclusively presume has already been done. But it is urged that the Act is unconstitutional as to all the defendants, because it violates the contract of the original lease.

The law in regard to legislation of this character is fully and clearly stated by Judge Cooley in his work on constitutional limitations, on p. 367 et. seq. He says: “It must be evident that a right to have one’s controversies settled hy existing rules of evidence is not a vested right. These rules pertain to the remedies which the State provides for its citizens, and generally in legal contemplation they neither enter into and constitute a part of any contract, nor can be regarded as being of the essence of any right which a party may seek to enforce. Like other rules affecting the remedy, must therefore at all times be subject to modification and control by the Legislature. * * * But the Legislature has no power to establish rules which, under' pretense of regulating the presentation of evidence, go so far as altogether to preclude a party from exhibiting his rights.”

Now, it will be observed that the Act in question simply prescribes a period, after which it shall be conclusively presumed that a new lease has been executed in favor of the [19]*19lessees, unless in tlie meantime the lessors, by their action of ejectment or otherwise, have disturbed their, possession. It is substantially, therefore, in fact, although not in terms, an Act of limitations, requiring the lessors to bring their suit for the recovery of the demised premises within twelve months from the date of the expiration of the lepse, or from the passage of the Act. Our statute in regard to sealed instruments, which says no “bill obligatory, &e., or other instrument under seal, shall be offered in evidence after the lapse of twelve years from its date”; the several statutes in England, shortening the period of title by prescription (see Best on Ev., p. 481 et seq.), particularly Lord Te.nterden’s Act, which says that “after the lapse of thirty years the title of the party in possession shall be absolute and indefeasible”; are similar instances of legislation, which have always been held to be based upon sound legal principles. So that no matter what the words of the Act may be, whenever its effect is to regulate, or impose new conditions upon the exercise of, the remedy, it is held not to impair the obligation of the contract. But, under pretense of changing the remedy, or making a new period of limitations, the Legislature has no right to pass a law which will wholly prevent a party from having any remedy upon his contract. An Act, prescribing a new period of limitations, must always allow a reasonable time for the enforcement of contracts in existence at the time of its passage, if it is made applicable to such contracts. Thus, in the case of the State vs. Jones, 21 Md., a statute was passed shortening the period of limitations upon constables’ bonds from twelve to live years, from their date; it was held that the Act was constitutional against the plaintiff in that case because he had five months after its passage in which he could have brought his suit, although, before the new Act, he was entitled to six years longer in which to bring it under the old Act. The Court held that five months was a reasonable time within which the Legislature might require the suit to be brought.

Free access — add to your briefcase to read the full text and ask questions with AI

Cite This Page — Counsel Stack

Bluebook (online)
1 Balt. C. Rep. 17, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phipps-v-worthington-mdcirctctbalt-1888.