Smith v. Fulton

31 Ohio N.P. (n.s.) 49
CourtLucas County Court of Common Pleas
DecidedAugust 5, 1933
StatusPublished

This text of 31 Ohio N.P. (n.s.) 49 (Smith v. Fulton) is published on Counsel Stack Legal Research, covering Lucas 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
Smith v. Fulton, 31 Ohio N.P. (n.s.) 49 (Ohio Super. Ct. 1933).

Opinion

Martin, J.

In connection with the liquidation of the closed banks in Toledo, quite naturally there has arisen the necessity of finding and fixing the rights of the many persons who have given mortgages on their properties to some one or more of these closed banks.

Some six or more cases were presented to the court, each representative of a class but all involving the question of the right to off-set the bank deposit of the mortgagor against his mortgage indebtedness.

After the hearing of these cases it developed that in some of the banks certain mortgages had been grouped into trusts designated in each instance either by number or by name, and that against these mortgages so grouped there had been issued and sold certain certificates of participation. Certain holders of these certificates were given the privilege of intervening in the cases under consideration, so additional hearings were necessary. To the court it seemed desirable to decide all of these cases in one opinion, so court action in that particular was deferred awaiting briefs, the last brief being filed just a few days ago.

In this connection I want to commend counsel representing all of the parties engaged in this litigaton, for the very careful manner in which they have briefed the questions involved, and particular commendation is due Mr. Nolan Boggs, representing the Banking Department, in that he has fully recognized the fact that the Superintendent of Banks is in a position where he necessarily represents all classes, so that Mr, Boggs’ brief was in no sense partisan but was so prepared as to advise the court of all the hold[53]*53ings upon the questions involved, regardless of whether such holdings were for or against any propositions that might be involved in these cases, all of which made this brief of particular value to the court in determining these questions.

As indicated above, all these cases involve the right of set-off. The doctrine of set-off arose in the first instance out of necessity and in deference to the demands of equity and good conscience. That the demands of parties mutually indebted should be set off against each other and only the balance recovered, was very early recognized by courts of equity as being absolutely necessary to the proper administration of justice, and following the practice of this principle by' courts of chancery, general statutes have been enacted in most of the states, including Ohio, securing this right of set-off to parties standing in the relation of debtor and creditor and between whom there are cross demands, leaving of course unimpaired the right of a court of equity to apply the doctrine of equitable set-off — ¿that is, the right to grant relief in instances where equity and good conscience seem to demand it, and where a strict construction of the statutory law would not permit. The statutory right and the equitable right both maintain in Ohio.

It would serve no good purpose to review the decisions either of Ohio or of other states in the union on the basic principle of set-off. It may be admitted that there is disagreement between the laws and the decisions of the various states, but so far as Ohio is concerned, we have statutory off-sets, and by decision of the courts, a generous measure of equitable off-sets. Further than this, the doctrine of set-off, both legal and equitable in Ohio, applies as between a bank and its customers with the same force and effect as between debtors and creditors generally. These rights as between a bank and its customers, are reciprocal.

The law gives to a bank a general lien upon the deposits, papers, securities, etc. of its debtor in its possession. Also the right to set-off .against deposits, claims owing to them by depositors. And depositors on the other hand are given reciprocal rights in that they may have their deposits applied on the payment of their notes upon insolvency of the [54]*54bank. In other words, this right of set-off in favor of a depositor being available against the bank while the bank is solvent, is not affected by the insolvency of the bank but continues to be effective thereafter. 5 Ohio Jurisprudence — (Banks) Sections 96 and 136.

In that connection however, it ought to be borne in mind that this reciprocal right of set-off as between the bank and its customers is fixed and determined as of the time the bank becomes insolvent, or possibly when its insolvency is recognized by the closing of its doors and the taking possession of it by the proper authorities for liquidation, so that a person indebted to a bank may not be permitted, as a matter of right, to set-off against his indebtedness, a deposit which he had acquired by assignment after the closing of the bank. It is of course possible for him to do so by agreement with the Banking Department by way of compromise of his indebtedness but not by way of set-off as a matter of legal right.

This very general statement of the law seemed to me to be necessary to make understandable the opinion of the court upon the issues that have been presented in the representative cases which were heard by the court. In all of these cases off-sets are sought by the mortgage d'ebtor, and in all of the cases the mortgages in question have either been sold and conveyed to some third person by the bank or in some fashion encumbered by some interdepartmental transfer of such mortgage from one department of the bank to another department, and the subsequent issuance by the bank of certificates of participation, such certificates being a charge upon the income, both principal and interest, of these mortgages.

Necessarily therefore, the inquiry is, are these transactions of such a character as to deprive the mortgage debtor of his right of off-set? In other words, have any equities of third persons intervened by virtue of these transactions, and if so are they of such force as to defeat the right of off-set of the mortgage debtor?

In the case of Smith v. Fulton, No. 134031, the plaintiff alleges that she was indebted to The Ohio Savings Bank in the amount of $1610.00 on July 30, 1931; that the note and [55]*55mortgage securing this indebtedness was due and payable on February 28, 1931; that on July 30, 1931, the bank assigned the note and mortgage to the defendant, The Metropolitan Life Insurance Company without notice to or the consent of the plaintiff.

Plaintiff alleges further that the Ohio Savings Bank was indebted to her at the time of the closing of the bank, August 15, 1931 in an amount very greatly in excess of the amount due upon the mortgage; that she has been denied the right to have any portion of her deposit credited on this note and mortgage. Other allegations appear in the petition which do not become important in determining the basic question involved in the case.

The allegations in the petition were proven practically as alleged at the hearing of the case.

The inquiry is, is the plaintiff entitled to this off-set? This court is clearly of the opinion that she is entitled to the off-set. The bank, of course, had a lawful right to dispose of the note and mortgage of the plaintiff, and undoubtedly, if the note and mortgage in question had not matured at the time of their assignment, the plaintiff would have been defeated in her right of off-set. However, it is undoubtedly the law in Ohio that the assignment of a promissory note, after maturity, is subject'to set-off by the maker.

In the case of Baker v. Kinsey, 41 O. S. 403, the court says:

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Related

Knickerbocker v. Wilcox
47 N.W. 123 (Michigan Supreme Court, 1890)

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Bluebook (online)
31 Ohio N.P. (n.s.) 49, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-fulton-ohctcompllucas-1933.