Simmons v. Standard Publishing Co.

4 Ohio N.P. 89
CourtOhio Superior Court, Cincinnati
DecidedJuly 1, 1897
StatusPublished

This text of 4 Ohio N.P. 89 (Simmons v. Standard Publishing Co.) 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
Simmons v. Standard Publishing Co., 4 Ohio N.P. 89 (Ohio Super. Ct. 1897).

Opinion

Smith, J.

This is au action brought by plaintiff to enjoin.the defendant from ■discharging the plaintiff from its employment.

So far as the question presented to me for decision is concerned, the facts of the case may be stated briefly as follows:

On December 1, 1888, the Standard Publishing Company entered into a contract, in writing, with H. C. Hall, by which Hall was to have the entire management of the advertising department of said company. The agreement was to continue in force for three (8) years, with the privilege of a renewal'for two (2) additional years. The contract, therefore, expired on December 1, 1891, unless renewed for the additional two years.

On June 8, 1892, the same parties’entered into another contract, in writing, by which said Hall was to have charge of the advertisingdepartment of the Standard Publishing Company; and in this contract it was provided as follows:

“This agreement to continue in force during the period of five years from expiration of the present contract between said parties, dated December 1st, 1888.”

At the end of this contract appears in writing the following memorandum :

“Cincinnati, April 2d,’95.
“By and with the consent of the Standard Publishing Company, I heiv.by sell and assign all my title and interest in this contract to H. L. Simmons for value received. ”

And this memorandum is signed by H. C. Hall and Russell Errett, the president of the Standard Publishing Company.

The Standard Publishing Company claims that the contract expired at the end of five (5) years from the termination of three (8) years from December 21st, 1888. Whereas, the plaintiff contends that the contract did not expire until five (5) years from the expiration of the two years [90]*90renewal provided for in the contract of December 1, 1888, which would be December 1, 1893, making the contract still in force between the parties until December 1, 1898.

The dispute between the parties grows out of the use of the word “present” ln the contract of June 3, 1892. If at that date there existed, as recited in the contract of that date, a “present contract between said parties, dated Deoember 1, 1888,” the presumption is that it existed by virtue of the renewal for the additional two years provided for in the contract of Decemher 1, 1888 The plaintiff contends that the Publishing Company can not be permitted to show by parol evidence that there was no “present contract,” because such parol evidence would vary and contradict the express terms of the written contract; whereas the Publishing Company contends that as a matter of fact no-renewal of the contract of December 1, 1888, was ever made, and that the word “present” was used in the contract of June 3, 1892, by mistake, the draft of the contract having been made prior to December 1, 1891.

The Publishing Company has offered evidence tending to show that no present contract was in existence either on June 3, 1892, or on April 22, 1895. To the introduction of this evidence the plaintiff objects. The case turns upon the question whether such evidence is admissible.

If evidence tending to show that in fact there was no “present contract” is admissible, it must be upon one of two grounds. 1. That its insertion was by mistake, and that either party is entitled to have the contract reformed and made to read as if the word “present” were in it; or 2nd, that the statement that a “present contract” existed is a mere reoital of fact which muy neverthelesss be disputed if the surrounding circumstances which may always be put in evidence, show that such fact did not exist.

In considering this question, however, it must be remembered that the contract of June 8, 1892, was between the Publishing Company and Hall, between whom the contract of renewal was made, if made at all, and both of whom would, therefore, he familiar with the fact; biff, that by the memorandum of agreement of April 22, 1895, by and with the consent of the Publishing Company,Simmons was substituted in place of Hall as a party to the contract of June 3, 1892, and that Simmons may or may not have known that there was no “present contract, ” as recited in the contract of June 8, 1892.

The contract of April 22, 1895, was what is known in law as a novation, by which one party to a contract is released from his obligations under it, and another party substituted in his place. It differs from the mere assignment of a chose in action, which docs not require the assent of both parties to the original contract, whereas a novation does, and is, in effect, a new contract, between that one of the original parties who remains a party to the contract, and the new party who is taken in by way of substitution. No further consideration than the release of the outgoing party and the substitution of the incoming one is necessary to sustain the contract. 16 American & Eng. Ency. of Law, 862; 1 Beach on Modern Law of Contracts, section 786; 6PIarvard Law Review, 184; Bacon v. Daniels, 37 Ohio St., 279, 281.

As between the Publishing Company and Hall,if the pleauings properly present the question, there can be no doubt that evidence showing the insertion of the word “present” by mutual mistake would be admissible. But would it be admissible upon this ground against the contract by novation unless the party offering such evidence also offers to show that the substituted party was also aware of the mistake? It seems to me that upon the well settled principle of equity that relief will not be given unless the mistake is mutual, such evidence is not admissible.

[91]*91In Pollock on Contracts, (6th Ed.) 498, Wald’s Notes, it is stated and the statement is abundantly sustained by the authorities there cited:

“The court will not rectify an instrument when the result of doing so would be to affect interests already acquired by third parties on the faith of the instrument as it stood.”

And in other cases the principle is differently stated, as follows:

“Courts of equity will not interfere to correct a mistake in a written instrument to the prejudice of a hona fide purchaser as he has at least an equal right to protection with the party laboring under the mistake.” Gibson v. Cook, 2 Blatchford, 144, 150, a case as to the assignment of a patent right.
“It is a settled principle that a court of equity will not rectify a mistake in a written instrument by the aid of parol evidence except as between the original parties. As against bona fide purchasers without notice the instrument must stand as written. ”

Kilpatrick v. Kilpatrick, 23 Miss., 124, 129; Hewitt v. Powers, 84 Ind., 295, 299: Langdon v. Keith, 9 Vt., 299, 300.

It is urged by counsel for the Publishing Company,that Simmons in this case is not a bona fide purchaser within the sense in which that term is used in the authorities cited, for the reason that a bona fide purchaser in equity means one having the legal title, and Simmons in this case has no legal title.

It seems to me that the rule thus contended for is too narrow, and that the true rule is as stated in 1 Storys’ Eq. Jur. (13th Ed.), sec.

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Related

Langdon v. Keith
9 Vt. 299 (Supreme Court of Vermont, 1837)
Hewitt v. Powers
84 Ind. 295 (Indiana Supreme Court, 1882)
Kilpatrick v. Kilpatrick
23 Miss. 124 (Mississippi Supreme Court, 1851)

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Bluebook (online)
4 Ohio N.P. 89, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simmons-v-standard-publishing-co-ohsuperctcinci-1897.