Schaettle v. Benedict

1 Disney (Ohio) 445
CourtOhio Superior Court, Cincinnati
DecidedJune 15, 1857
StatusPublished

This text of 1 Disney (Ohio) 445 (Schaettle v. Benedict) is published on Counsel Stack Legal Research, covering Ohio Superior Court, Cincinnati primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schaettle v. Benedict, 1 Disney (Ohio) 445 (Ohio Super. Ct. 1857).

Opinion

Gholson, J.

The question presented in this case is whether [447]*447the plaintiff, under the circumstances shown by the evidence, could properly exercise the right of stoppage in transitu. It has been conceded that this right, if it otherwise existed, was not affected by the seizure of the goods under an order of attachment. Nor is there any difficulty upon the point as to which, in such cases, the difficulty most frequently arises; the right of the plaintiff was undoubtedly asserted before the goods had reached their destination. The transit had, indeed, commenced; but, from the circumstances, it may be inferred, that the process under which it was first arrested, had its commencement at a period fully as early. The only doubt, therefore, as to the right of the plaintiff, depends upon a question and it is the only question whieh has been presented and argued, as to the insolvency of the vendee. It is claimed for the defendant that the right of stoppage in transitu exists only in a case of insolvency on the part of a vendee; that no such insolvency as the law requires is shown by, or can be inferred from, the evidenee in this case; that the insolvency whieh may be inferred existed at the time of the sale; and that, to authorize the stoppage in transitu, it must have occurred after the sale, and have been evidenced by some overt act.

The mercantile law appears to be clear and distinct that where goods have been consigned, and are in transit to the vendee, the consigor can not vary the consignment except in the case of insolvency. It has been said, that “ the mischief and inconvenience that would ensue on a contrary supposition are extreme. The goods might be put on board, and might lie at the risk of the consignee for two or three months; and if the consignor could come and resume them at pleasure, it would place the consignee in a situation of great disadvantage ; that he should be exposed to the risk during such a length of time, for an object which might be eventually defeated, at any moment, by the capricious or interested change of intention in the breast of the consignor. It would be to expose the consignee altogether to the mercy of the seller:" The Constantia, 6 Rob. Adm. 321-327. In the language of the same high authority, in that case where a vendor had [448]*448stopped and diverted the delivery of goods, if the vendee “ had been an insolvent person, it would have amounted to a complete and effective revendication of the goods. But if the person to whom they are consigned is not insolvent; if, from misinformation, or from excess of caution, the vendor has exercised this privilege prematurely, he has assumed a right that did not belong to him, and the consignee will be entitled to the delivery of the goods, with an indemnification for the expenses that may have been incurred.” * * “It is not an unlimited power that is vested in the consignor, to vary the consignment at his pleasure in all cases whatever. It is a privilege allowed to the seller, for the particular purpose of protecting him against the insolvency of the consignee. Certainly it is not necessary that the person should be actually insolvent at the time. If the insolvency happens before the arrival, it would be sufficient to justify what has been done, and to entitle the shipper to the benefit of his own provisional caution. But if the person is not insolvent, the ground is not laid on which alone such a privilege is founded;” 6 Rob. Adm. 326.

The exposition of the law on this subject, which has been quoted from the judgment in the ease of The Constantia, has been several times cited with approbation. In 2 M. & G. 792, 811, Wilmshurst v. Bowker, which was an action by a vendee against a vendor for improperly stopping the delivery of goods, it was said by Tindal, C. J.: “ The ordinary right of countermanding the actual delivery of goods shipped to a consignee, is limited to the eases in which the bankruptcy or insolvency of the consignee has taken place. The law as to this point is very clearly laid down by Lord Stowell, in the case of The Constantia.” Certainly it would seem that the principles recognized by Lord Stowell as governing such cases, do not countenance the idea that a vendee, insolvent at the time of the sale of the goods, and still remaining insolvent, could object to their stoppage in transitu. The only conceivable case, according to those principles in which such a vendee could complain, would be where his insolvency was [449]*449known to the vendor at the time of sale, and the contract was made in view of his condition. The very object of granting the privilege to the vendor is to protect him from the insolvency of the vendee, and the privilege, unless waived by the vendor, must properly extend to cases of insolvency, whether existing at the time of sale, or occurring at any time before the actual delivery of the goods.

A vendee who disputes the right of stoppage in transitu, and claims an indemnity for its improper exercise, must be prepared to aver, as in the case of Wilmshurst v. Bowker, that he was neither bankrupt nor insolvent. Under such a negative averment, independent of any circumstances to the contrary, the vendee might have the benefit of a presumption of ability to comply with his contract, and the burthen of showing insolvency might be cast on the vendor. It may be that this would be sufficiently shown by the proof of an overt act of insolvency, such as a stoppage of payment, though in fact an actual insolvency, in the sense of not having means adequate to the payment of debts might not exist. If the vendee, before the stoppage in transitu, had, by his conduct in business, afforded the ordinary apparent evidences of insolvency, he ought not to complain of the precautionary measure taken by the vendor, though it should turn out that he was ultimately able to pay. But though no such evidences of insolvency should precede the stoppage in transitu, still, if the fact of insolvency existed, the vendee could not complain. This, at least, is clearly to be inferred from the language of the authority which has been cited, and appears entirely reasonable and proper. If an adventurer without means purchases goods, no inquiries and no representations being made, there may be no actual fraud in the transaction, but unless his condition was fairly and frankly stated to the vendor, so as to show that the sale was made with a waiver, expressed or implied, as to the inability to pay, he can not properly object to a stoppage in transitu. In such a case, the pretense that, there having been no means on which to predicate a failure, except those expected from the purchase, there have been no [450]*450overt acts of insolvency, should not be allowed to prevail. Eair dealing will be better insured by leaving to the vendor his privilege of stoppage in transitu, in all cases of insolvency, whether evidenced by the ordinary accompanying acts, or shown actually to exist. The rights of a fair vendee will be sufficiently protected by giving him an indemnity when the right of stoppage in transitu is exercised upon rumor or suspicion without any foundation in fact, and by depriving the vendor, in all cases, of any chance of speculating upon the goods, by requiring them to be delivered or accounted for to the vendee, or his assignees on the payment or tender of the agreed price.

In opposition to these views is the decision of the Supreme Court of Connecticut, in 20 Conn. 53, Rogers v. Thomas,

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Related

Rogers v. Thomas
20 Conn. 53 (Supreme Court of Connecticut, 1849)

Cite This Page — Counsel Stack

Bluebook (online)
1 Disney (Ohio) 445, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schaettle-v-benedict-ohsuperctcinci-1857.