Seibert v. Citizens Fire Insurance

12 Ohio N.P. (n.s.) 210

This text of 12 Ohio N.P. (n.s.) 210 (Seibert v. Citizens Fire Insurance) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Seibert v. Citizens Fire Insurance, 12 Ohio N.P. (n.s.) 210 (Ohio Super. Ct. 1912).

Opinions

Kinkead, J.;

Bigger, Rathmell, Evans and Rogers, JJ., concur.

The case was submitted upon demurrer to the petition for misjoinder of causes of action. Plaintiff unites causes of action upon two separate contracts of insurance made by plaintiff with two insurance companies upon the same property.

.The petition in this case, and each cause of action thereof, contains the following averment:

“Plaintiff says that he effected other insurance on the above-described property to the amount of $2,000 with the other defendants herein, German-American Insurance Company and German Alliance Insurance Company; that said policy issued by said defendant, Citizens Fire Insurance Company, specifically provided that permission was given in said policy for other insurance ; that said policy issued by said defendant, Citizens Fire [211]*211Insurance Company, provided therein that said company should not be liable for a greater proportion of any loss on the property above described than the amount of said policy issued by said defendants, Citizens Fire Insurance Company, should bear to the whole insurance upon said property.”

It is urged in opposition to the demurrer that the above allegation justifies the joinder of the two causes of action against the different companies; that the joinder is proper because the contracts of insurance made by plaintiff with the German American Insurance Company and the German Alliance Insurance Company provided that the insured may obtain other.insurance upon the property, 'and because each of the policies contains the provision as to proportionate liability.

The court on a previous hearing overruled the demurrer and held that the causes were properly joined.

This conclusion wias at variance with the decision of Bigger, J., in Superior Mantle Co. v. Underwriters Mutual Fire Ins. Co., 4 O. L. R., 432 (17 O. Dec., 118). Upon application a rehearing was granted and the question has been re-examined by the writer of this opinion. And upon request of counsel and because of the importance of the question -as a rule >of practice, the matter was taken up and considered by all the members of this court. The concensus of opinion is that the rule of decision by Bigger, J., in case above cited should be adhered to, and the demurrer to the petition for misjoinder of causes is, therefore, now sustained.

The ruling previously announced permitting the joinder was based upon the precedent established in Fegelson v. Insurance Co., 94 Minn., 486, and Pretzfelder v. Insurance Co., 116 N. C., 491, which sustain the right of joinder in such cases. The reasons upon which these two courts sustain the joinder appeals strongly to one’s sense of justice, resulting in the settlement of the loss sustained in one trial, where practically the same evidence, and possibly the rules of law may be the same.' The grounds upon which the decisions are based are because the contract with each company contains the provision that the [212]*212plaintiff’s right of recovery against each is limited to the proportion of the loss which the amount named in the policy of each company should bear to the whole amount insured; and because by a separate action on each policy the same proposition of law would arise and the same evidence would be gone over in the different oases, adding costs, and at needless consumption of the time of the courts. These decisions argue also that there is no method to gauge accurately the pro rata loss of each company so readily as by one verdict and one apportionment according to the varying amount of risk taken by each company. It is said that:

“By their stipulation to apportion the loss the company have to that extent at least, made the five policies one contract, the amount of damages accruing upon which should be assessed and apportioned in one joint action.”

In the Minnesota decision it is considered that the joinder is proper because it is necessary in order to determine the amount which plaintiff is entitled to recover against each defendant, to determine conclusively as against each company two questions in which there is a community of interest among all the defendants, namely, the amount of the plaintiff’s loss and the amount' of his valid insurance upon the property lost or damaged by fire. It is considered that if the insured can not bring all the companies into one action, and have these questions determined as a basis for accurately and conclusively ascertaining the pro rata liability of each insurer for his loss, he is without any certain, speedy, adequate and convenient remedy, and he is remitted to the uncertain remedy of a multiplicity of suits. The remedy by separate suits is claimed to be neither certain nor adequate, depending upon the aggregate result of a multiplicity of vexatious actions.

In the North Carolina case the court considered that “By their stipulation to apportion the loss the companies have to that extent at least made the five policies one contract, the amount of damages accruing upon which should be assessed and apportioned in one joint action.”

[213]*213The complaint in the case of Fegelson v. Insurance Co., 94 Minn., 486, prayed that the court will ascertain the facts and the amount of the plaintiff’s loss, and the proportionate share thereof of each defendant, and award judgment accordingly. The'parties evidently were endeavoring to make the causes of action equitable in nature.

Such a conception of a case of this kind when properly presented by a petition in that form finds favor with some of the members of this ootirt.

But the joinder of causes of action in equity are to be measured by the same tests as those at law. And the violation of each primary contractual right gives rise to separate causes of action, and 'causes of action for the violation of separate contractual rights can not be united in the same petition, unless they come within- the statute and arise out of the same transaction, or are connected with the subject of the action.

The Minnesota decision, however, contains a quotation from Pomeroy’s Eq. Jur., Section 269, to the effect that: “courts of the highest standing and ability have repeatedly interfered and .exercised this jurisdiction (to prevent multiplicity of actions), where the individual claims were not only legally separate, but were separate in time, and -each arose from an entirely separate and distinct transaction, simply because there was a community of interest among all claimants’ in the question at issue and in the remedy.”

This decision concedes that the pro rata liability provision does not make the liability of the respective companies a joint one, and that the liability of each is several, to be determined by the terms of its own contract (94 Min., 488; Bardwell v. Conway, 118 Mass., 465; Hanover v. Brown, 77 Md., 64). But it is insisted that the fact -of separate liability is not' decisive of the question, but that the community of interest’ by reason of the pro rata clause constitutes a well recognized exception to the general rule that several causes of action can not be united to enforce separate liability of several defendants. The same view was taken in Virginia-Carolina Chemical Company v. Home Ins. [214]*214Co.,

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Related

M. Pretzfelder & Co. v. Merchants' Insurance
21 S.E. 302 (Supreme Court of North Carolina, 1895)
Bardwell v. Conway Mutual Fire Insurance
118 Mass. 465 (Massachusetts Supreme Judicial Court, 1875)
Hanover Fire Insurance v. Alexander Brown & Sons
25 A. 989 (Court of Appeals of Maryland, 1893)
City of Albert Lea v. Nielsen
86 N.W. 83 (Supreme Court of Minnesota, 1901)
Fegelson v. Niagara Fire Insurance
103 N.W. 495 (Supreme Court of Minnesota, 1905)

Cite This Page — Counsel Stack

Bluebook (online)
12 Ohio N.P. (n.s.) 210, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seibert-v-citizens-fire-insurance-ohctcomplfrankl-1912.