Renton v. St. Louis

1 Wash. Terr. 215
CourtWashington Territory
DecidedDecember 15, 1867
StatusPublished

This text of 1 Wash. Terr. 215 (Renton v. St. Louis) is published on Counsel Stack Legal Research, covering Washington Territory primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Renton v. St. Louis, 1 Wash. Terr. 215 (Wash. Super. Ct. 1867).

Opinion

Opinion by

Darwin, Associate Justice.

The plaintiff filed a complaint for goods sold and delivered. The defendants demurred that it did not state facts sufficient to constitute a cause of action, and the demurrer was sustained. The complaint was also dismissed and an attachment based upon it dissolved. The plaintiff appeals. Under our law, which is in the spirit of the “Reformed Practice,” and nearly conforms to the letter of the New York code of civil procedure, the substantial requirement of the complaint is that it states facts sufficient to. constitute a cause of action. (Sec. 53, Practice Act.)

If a man has a legal right against another, it is because a set of facts generate the right; or more exactly speaking, it is because a certain set of statements or fact-propositions may be truly predicated of their relation to each other. Now if he wants to enforce that right he must enter a complaint which states these fact-propositions, and if denied must prove them. This procedure and requirement conforms to common reason and ordinary logic. The defendant is apprised of what facts the plaintiff bottoms his claim upon and can either prepare to dispute their existence, or conceding that, to dispute that they establish the right demanded. The court called upon to decide the controversy can see clearly what it is, and can determine whether it has the right to decide or not, and when the decision has been made, the facts that have been decided will remain manifested by the archives.

In early times a logic as simple as the above presided over the pleadings, but it was soon abandoned, and there was gradually introduced a technical and artistic system which interposed innumerable difficulties to the pursuit of justice. For now many years these impediments have been diminishing, but until [217]*217lately there was a number of forms on legal envelopes labeled as debt, covenant, detinue, trespass, trespass on the case, replevin, etc., within the jealous embraces of some one of which the plaintiff was required to introduce his facts to the Court, and if he brought ever so good a case for relief under a mistaken label, he was dismissed as severely as if. the merits were against him. The labeling and the style of envelope had come to be regarded as an essential part of the case itself. But to-day according to our reformed practice, if the plaintiff state the facts, which under the law establish a cause of action, the more informal, ordinary and untechnical the language used, the better, and the cause is unassailable by demurrer, if its statement constitutes a right to a remedy. It will be seen then that the function of the demurrer is not the same under our law that it was under the old practice. There were formerly two kinds; the general demurrer, which put in issue the sufficiency of the statement, and which also comprehended the form of action, and the special demurrer which was used to assail defects and details of form. Our demurrer is not according to the common law, either a general or a special demurrer, but one whose powers and sufficiencies are governed entirely by our civil practice act. It is a new creation; the old rules have no value, and indeed would mislead us in defining its uses; it has no fitness nor applicability except in the very instances expressed by the act. There are now only six faults which are assailable by demurrer, and they are all defined in Section 54.

A complaint, however, which is in full conformity to that section, and so is quite invincible to demurrer, may be nevertheless very faulty otherwise, as for instance it may have excess and contain improper matter, or may be defective, or so indefinite and undescriptive as to be uncertain, and that sort of a fault which formerly called into requisition the special demv/rrer is now only corrigible by motion. Section 70 provides a motion for removing excess, and another for supplying deficiency, and the motions of this section and the demurrers of Sec. 54, each used in its own statute province are all the appliances now permissible for the attack or reformation of any pleading. The [218]*218object of our system is to abolish all the merely formal requirements and technical impediments which had become by ages increased into pleadings, and to restore common sense and retain alone sound logic. Whether a common law form is good or not, now will not depend on what the old practice said of it, but on what the new one says. All the old forms contain far more verbiage than is needed under our law, many of them would not be demurrable, most of them would be obnoxious to the motions of Sec. 70, and none of them are so concise and ordinary in phrase as to comply with the curt and crisp business sense of our act.

The complaint in question is a “common count for goods, wares and merchandise sold and delivered.” It contains irrelevant matter and legal propositions of which it might have been jmrged by the motion of Sec. 70, but it nevertheless contains fact-propositions enough to show that the defendant was indebted to the plaintiff and thus states a cause of action and is therefore proof against a demurrer.

While our practice act by sections 2 and 50 thereof, abolishes all common law forms of action, it does not abolish the statements used in them. It rather signifies that their form, or any form whatever is unnecessary, than" discloses their statements to be in any case utterly inapplicable. The use of a common count indicates a misapprehension of the meaning of the code, betrays a painful want of sympathy with its excellent common sense, supposes a mechanical rather than a logical acquaintance with pleading, and should be discouraged but only so far as may be consistent with the spirit of a system which even declines to push its own utterances to the extremity of hindering or delaying justice. A common count however would not be good or bad now as it conformed or not to common law rules, but as it conformed to the provisions of the practice act, that is, it would be invulnerable to demurrer if it stated facts enough to be a cause of action, and to motion if it had no excess or deficit, that is, if it did not violate Sec. 54 nor Sec. 70, it would be a good complaint and conformity with 54 is to be tested by demurrer, and with 70 by motion.

[219]*219A complaint may state sufficient facts to constitute a cause, and may also in excess state other matter which may be quite irrelevant, or which may be re&wndamt, or which may be the testimony by which such facts are to be established. Or it may, while it states a cause of action do so in statements so general as not to difference the cause sued on from some other cause with the defendant, which uncertainty the defendant may cause to be diminished or removed by the motion of Sec. 70. If a complaint be good against a demurrer the defendant will seldom object that it states more than it need do, that it states something irrelevant or redundant, or that -it states needlessly the testimony by which plaintiff expects to sustain his facts, but if he chose to object by the motion of Sec. 70, the plaintiff may be chastised into conformity to the code.

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Bluebook (online)
1 Wash. Terr. 215, Counsel Stack Legal Research, https://law.counselstack.com/opinion/renton-v-st-louis-washterr-1867.