Robinson v. Easton

14 Ohio C.C. (n.s.) 87, 1911 Ohio Misc. LEXIS 177
CourtFranklin Circuit Court
DecidedFebruary 7, 1911
StatusPublished

This text of 14 Ohio C.C. (n.s.) 87 (Robinson v. Easton) is published on Counsel Stack Legal Research, covering Franklin Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robinson v. Easton, 14 Ohio C.C. (n.s.) 87, 1911 Ohio Misc. LEXIS 177 (Ohio Super. Ct. 1911).

Opinion

The plaintiff below brought an action against the defendant below for damages alleged to have occurred by the falling of a derrick upon the plaintiff, whereby the plaintiff was injured, said derrick having fallen by virtue of alleged negligence of the defendant below in not repairing or, having a proper guy.

To the petition the defendant filed an answer of general denial and also alleged contributory negligence, and as a third defense set up the following:

‘ ‘ That before this action was brought and that no alleged cause of action having accrued for plaintiff’s said injuries, to-wit, on the 4th day of February, 1907, these defendants paid to the plaintiff herein in compromise and satisfaction of any and all claims or causes of action arising out of said injuries, the sum of [88]*88$29.25. That said plaintiff accepted the same in full satisfaction and discharge of any and all claims or causes of action arising out of his said injuries; that said plaintiff executed and delivered to defendants a release in writing, a true copy of which is as follows: ‘Received of the Columbus Hoop Company this 4th day of February, 1907, the sum of $29.25 in full satisfaction and discharge of all claims accrued or to accrue in respect of all injuries or injurious results, direct or indirect, arising or to arise from an accident sustained by me on or about the 15th day of January, 1907, while in the employment of the above.
“ ‘Witness: C. Y. Easton.
“ ‘Winifred Altwater,
“ ‘Address, 276 E. 11th Avenue.’ ”

To this answer plaintiff filed a reply admitting that on or about the 4th day of February, 1907, he signed some instrument of writing and admits that he received about $29.25 at said time Plaintiff denies that he ever agreed to accept said money in full satisfaction and discharge of any claims or causes of action arising out of said injuries, and alleges that if the said writing which he did sign purports to be a receipt in full satisfaction and discharge of any or all claims for causes of action arising out of his said injuries, he was ignorant of that fact; that his signature thereto was obtained by false and fraudulent representations on the part of defendants in this, to-wit:

“That defendants represented to plaintiff that said writing was merely a receipt for wages due him from said defendants: that plaintiff relied upon the said representations, and, believing them to be true, signed said writing without reading the same or knowing what it contained. ’ ’

The case was tried to a jury and a verdict returned for the plaintiff. A motion was made by the defendant for a new trial which -was overruled, and error was prosecuted to this court.

The principal errors relied upon by the plaintiff in error for reversal of judgment are two: The first being that the issue raised by the pleadings upon the matter of the release would not warrant a judgment for plaintiff, because there was no tender pleaded of the amount received in the release, and that neither the pleadings nor the evidence showed that it was that kind of a [89]*89contract that could be set up as a defense without pleading tender of the money received or having the instrument first reformed by a court of equity.

In the case of Perry v. O’Neil, 78 O. S., 200, we have this in the syllabus:

“A release of a cause of action for damages for personal injuries that is void is not a bar to such an action, and the plaintiff may, if it is set up by answer as a bar to his right of action, by reply, aver the facts that make it void. But if it is not void but only voidable, he can not maintain his action until the reléase is set aside.”

This decision of the Supreme Court is unfortunate in not making clearer what is intended to be. included or necessary to constitute a void contract within the language of the syllabus. That it might be meant to include such a contract as the one under consideration, even though it were not what is ordinarily considered as a void contract is borne out from the opinion in the case as well as the construction that has been given thereto by other courts.

In the case of Railway v. Coleman, 12 C.C.(N.S.), on page 500, in considering a ease somewhat similar to the one at bar, we have this language of the court:

“If what I have read were established, it would appear that the release was absolutely void. If it were true that Coleman at the time was unable to read by reason of these injuries to his eye and if he was deceived by Mr. Latta, his superior in the employ of the company, as to the contents of the paper, if he signed the paper under such circumstances, supposing it to be one thing whereas it was an entirely different thing, that is to say, a mere matter of form that he must sign before he can work again, whereas it was a release of all claims against the company, if his signature was obtained under such circumstances and by such method, the release would be absolutely void, and under the authorities this issue of release might be- raised by reply setting forth the facts showing that the release was void. ’ ’

So, we are constrained to believe that what was intended by the Supreme Court was, that if the contract were such, in this kind of eases, that a court of equity could or would set it aside, that [90]*90the defense could be made that the contract was invalid without pleading a tender of the money received. The case in the 12th Circuit was affirmed without opinion by the Supreme Court. That this was the idea that pervaded the mind of the judge rendering the opinion in 78 O. S., 209, is clear from this language:

“If a party suing to recover for personal injuries admits the execution of a release and seeks to avoid it on equitable grounds, he must obtain that relief to maintain his action, when he denies the execution of the release, or that it is his act, on the ground of want of mental capacity at the time he signed it, or that his signature to the release was procured by fraud, such as misreading, the surreptitious substitution of one paper for another or obtaining by some other trick or device an instrument which he did not intend to give, he may maintain his action without obtaining a decree. In other words, if the release is void, he may ignore it in his petition, and if it is plead as a bar in the answer, he may in his reply plead the facts that make it void; if it is not void but only voidable, he must, to maintain his action, obtain its rescission or cancellation. ’ ’

And quoting further,, he says (p. 210) :

“At common law it has often been held incompetent to a defendant suing at law on a specialty to plead that the instrument was obtained by false representation: it is a case, it is said, for equity alone. It is clearly otherwise of the execution of the instrument, as where the bond is misread to the obligor, or where his signature is obtained to an instrument which he did not intend to sign. In such cases fraud may be alleged at law. ’ ’

In this opinion a large number of cases are given and quoted from where a release has been set aside without pleading tender of money received.

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Related

Chicago, Rock Island & Pacific Railway Co. v. Lewis
109 Ill. 120 (Illinois Supreme Court, 1884)

Cite This Page — Counsel Stack

Bluebook (online)
14 Ohio C.C. (n.s.) 87, 1911 Ohio Misc. LEXIS 177, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robinson-v-easton-ohcirctfranklin-1911.