Schmidt v. Schmidt

1 Ohio N.P. (n.s.) 177
CourtVan Wert County Court of Common Pleas
DecidedJune 15, 1903
StatusPublished

This text of 1 Ohio N.P. (n.s.) 177 (Schmidt v. Schmidt) is published on Counsel Stack Legal Research, covering Van Wert County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schmidt v. Schmidt, 1 Ohio N.P. (n.s.) 177 (Ohio Super. Ct. 1903).

Opinion

Mathers, J.

In this action plaintiff seeks the reformation and specific performance of an alleged lease of a store-room in the village of Ohio City, the quieting of title thereto, and an injunction against the execution of a writ of restitution awarded by a justice of the peace in favor of the defendants, and against the plaintiff, in an action of forcible entry and detainer heretofore prosecuted.

The defendants plead, by way of defense, that the matters and things set up in the petition are res judicatahaving been submitted to a justice and a jury, in the action of forcible detention, and passed upon adversely to the plaintiff. They also deny the averments of fact in the petition upon which plaintiff predicates his claimed equities.

The petition herein plainly invokes the equity powers of this court by pleading facts and praying relief which a justice of the peace has no power to give. While this action may involve a review of the adjudication of the justice, yet there is.no objection to such, a proceeding, for Sec. 6601, Revised Statutes, expressly provides: “Judgments either before the justice or in the court of common .pleas, under this chapter (Chap. 9, Title III, regulating forcible entry and detainer), shall not' be a bar to any after action brought by either party.” And in Gladwell v. Hume, 18 C. C., at [178]*178p. 848, the court reasons well on the practical independency of such a proceeding before a justice and such an action as the one at b'ar.

It may be interesting to inquire why Section 6601 should contemplate that a defendant in an action of forcible entry and detainer might' desire to bring an “after action,” for it expressly provides that judgment shall not be a bar to “any after action brought by either party.” One reason is suggested by the questions involved in this very case at bar. If an equitable defense m'ay be interposed in an action of forcible entry and detainer, it is difficult to see why the judgment of the justice, if free from errors of law, should not be conclusive. If, however, such a defense can not be interposed in such an action, it is readily seen why some “after action” might be necessary, on the part of the defendant, to secure his rights.

Can, then, an equitable defense be made in an action of forcible entry and detainer, or forcible detainer, in Ohio? An inquiry into the nature of this action, and the jurisdiction of justices of the peace in this state, is -necessary to answer this question.

In Rothwell. v. Winterstein, 42 O. S., at page 250, it is said: “The action of forcible entry and detainer is special and statutory,” and in Carroll v. O'Conner, 25 O. S., at page 617, it is said that this action “is intended t'o be a speedy and summary mode for the recovery, in the cases specified in the statute, of lands and tenements.” As the right to possession of lands and tenements is the only right that' can be enforced in this action (Swan’s Treatise, 18th Ed., p. 569), and the right to possession is a legal right, as opposed to an equitable one, the action of forcible entry and detainer. or forcible detainer, is essentially a legal action. At common law, and under the practice in Ohio prior to the adoption of the Code of Civil Procedure, there could be no equitable defenses to legal actions, even in courts of general jurisdiction like the common pleas, much less in justices’ courts. This is changed by the reform procedure, so far as the common pleas and the superior courts are concerned, and a defendant is now permitted (Section 5071), to set up in his answer as many grounds of defense, counter-claim, and set-off as he may have, whether they are such as has been heretofore denominated legal or equitable, or [179]*179both. But the reformed procedure, commonly called “the Code,”. does not govern proceedings before justices of the peace. There are special statutes regulating such proceedings (Title III, Part Third, of the Revised Statutes). As it is only by virtue of the express provisions of the Code that the distinctions between legal and equitable proceedings are abolished, and as the Code does not relate to proceedings before justices of the peace, it follows that the latter are unaffected by the reformed procedure, except where otherwise provided. By Section 6705, the provisions of the Code, which are in their nature applicable to the proceedings before justices, are made to apply to such proceedings. Judge Swan (Treatise, 18th Ed., p. 24), calls this provision a “blind guide,” even to the legal profession, but reaches the conclusion that a justice of the peace has no equity powers for the reason that “the general jurisdiction of a justice, by the very terms of the statute, relates to the recovery of 'a sum of money, * * * and the bill of particulars, etc., mentioned in the justices’ act, are all based upon common law proceedings and common law judgments for money,” and says, “The provisions of the Code, therefore, in relation to equitable suits and chancery proceedings, * * * ere., are not ‘in their nature applicable to the jurisdiction or to proceedings before justices of the peace.’ ” As the jurisdiction of justices is, in its nature, legal only, Section 6705 can not operate to enlarge that jurisdiction, nor to modify its character. That section can only mean that those provisions of the ~Code, which relate to legal proceedings, are applicable to proceedings before justices of the peace, because* their jurisdiction is, in its nature, essentially legal in character.

But, while justices of the peace have no equity powers, i. e., power to grant equitable, as opposed to legal, relief, does it follow that they have no equity perceptions? That is to say, no ability to decide that the facts proved, in an action before them, show equities in one party or the other ? It might be urged, with reason, that in an action of forcible detainer, which, though undoubtedly purely legal, a defendant is not seeking to invoke any equity power on the part of the justice, by setting up an equitable defense; that he only asks the justice to determine if, on the whole case and the law of the land as applicable to the facts as they really [180]*180are, the complainant ought to recover possession. Judge Swan, in the chapter -on Forcible Entry and Detention (Treatise, 18th Ed., p. 576), s'ays: “If the lease was not in writing, but a mere verbal contract, it is binding, on both parties, provided the tenant took possession under it, precisely as if it was executed according to the prescribed rules of the statute,” and thus seems to imply that such a equitable defense is available in such an action. Let us see what the courts have decided on this question.

In Carey v. Richards, 4 W. L. M., 251, the court, in an exhaustive 'Opinion and analytical review of the authorities, decided (1) that a justice- of the peace has no equity jurisdiction or powers; (2) that a parol lease is not valid, 'at law, to create a term or title in the lessee; (3) that an action of' forcible detainer does not involve the exercise of equity jurisdiction, but is a law proceeding; (4) that while part performance of a parol lease will take it out of the operation of the statute of frauds, yet such part performance has no such effect at law; (5) that in actions of forcible detainer, a tenant in possession, in pursuance of a verbal lease, can not defend under it, against his landlord, upon the ground that part performance makes it' valid; and (6) that an equitable title can not be set up as a defense, before a justice of the peace, in an action of forcible detainer.

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Bluebook (online)
1 Ohio N.P. (n.s.) 177, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schmidt-v-schmidt-ohctcomplvanwe-1903.