Stagge v. Nichols

1 Ohio C.C. 408
CourtOhio Circuit Courts
DecidedJanuary 15, 1886
StatusPublished

This text of 1 Ohio C.C. 408 (Stagge v. Nichols) is published on Counsel Stack Legal Research, covering Ohio Circuit Courts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stagge v. Nichols, 1 Ohio C.C. 408 (Ohio Super. Ct. 1886).

Opinion

Cox, J.

The petition in this case was filed to compel the specific performance of a contract signed by Laura J. Nichols and her husband, to convey to plaintiff, in consideration of $18,500, a tract of land in Hamilton county, Ohio, which was the separate estate of the wife.

The contract was made on the 20th of August, 1885, and signed by both husband and wife. Five hundred dollars of the consideration was alleged to have been paid to defendants at the'date of the contract. The remainder of the purchase-money was to be paid, $7,000 on the first of March, 1886, the date of the delivery ofthe deed; the balance in six notes of $1,000 each, bearing interest payable in one, two, three, four, five and six years, and secured by a mortgage on the premises.

[409]*409The petition alleges that Laura J. Nichols now denies she has made such contract of sale, repudiates the same as far as she can, will not perform it, and threatens to, and will, unless énjoined by this court, sell and convey the premises to other persons unknown to plaintiff, before the first day of March, 1886, and has entered into negotiations to that end, being induced thereto by expectatiodof getting a higher price than the above amount; that the defendants are about to remove from this county, where they have resided for many years, to the state of Indiana; that said Laura J. Nichols has no other property except the premises sold to plaintiff. Plaintiff asks that she be enjoined from conveying the property to anyone else, and that the court upon a hearing of this case find that she made a contract of sale; that a decree of the court be made binding upon defendants, and that they be ordered to perform the contract at the time named by executing and delivering a deed to him upon payment of the money and the execution and delivery of the notes and mortgage mentioned in the contract.

To this petition a demurrer was filed, and also an answer.

The case was heard upon the questions of law as well as the •questions of fact.

The answer admits that the contract was signed, but denies that it was acknowledged by the wife separate and apart from her husband; denies all liability upon it; says it was not her voluntary contract, and offers to tender back the money already paid.

There is also an amended petition alleging that upon the first of March, the time when the amount of the purchase-money became due, the first payment was tendered, and also the notes and mortgage for deferred payments, and a deed demanded, which was refused.

The sole question in the case is, whether a married woman can be compelled to execute a contract in writing, made jointly with her husband, to convey her separate real estate, the contract not being in the shape of a deed, and there being no acknowledgment separate and apart from her husband.

The law in Ohio upon the rights and obligations of a married woman as to her separate property has been continually chang[410]*410ing and progressing for the last twenty-five years towards one point, and that is, to hold her liable upon all her contracts as if she were a feme sole. The first act passed in 1861, familiarly known as the Keys Act, provided that property which came to her during coverture by conveyance, gift, devise, or inheritance, or purchased by her separate money or means, together with all the rents and issues thereof, should be and remain her separate property and under her sole control, and that in her own name during coverture she could lease the same for any period not exceeding three years, and her personalty was placed under her sole control except where the property had been reduced to the possession of the husband with the assent of the wife. :

The act of March 80,1874, provided that in an action which concerned her separate property, or upon any written obligation, agreement or contract, signed by her, or action brought by her to set aside a deed or will, it was not necessary to join her husband in the action, but it could be prosecuted in her own name, “ and in all cases where she may sue or be sued alone, like proceedings shall be had, and like judgment had and enforced in all respects as if she were an unmarried woman ; ” that in every such case, her separate property and estate should be liable for any judgment rendered therein against her, to the same extent as would the property of her husband, were'the judgment against him; giving, however, the benefit of the exemption laws of the state.

Under this legislation the case of Phillips v. Graves, 20 Ohio-St., 371, was decided, which held that a married woman possessed of a separate estate in real or personal property may charge the same with her debts, at least to the extent that such debts may be incurred for the benefit of her separate estate, or for her own benefit, upon the credit of her separate property,” and, her intention to charge her separate property at the time may be either expressed or implied; ” that such intention may be inferred from the fact that she executed a note or other obligation for the indebtedness, and that courts of equity will énforce the payment-of such charges against her separate estate through a receiver, 1st, by appropriating her personal property; 2d, by sequestering the rents and profits of [411]*411the realty; and, 3d, by sale of the realty when the same is necessary; that the jurisdiction of courts of equity in this behalf is not abridged or taken away by the operation of the statutes “ concerning the rights and liabilities of married women;" and that the statute providing “for the proof, acknowledgment and recording of d'eeds and other instruments of writing,” is not incompatible with the equitable power of a married woman to charge her separate estate with debts incurred within the scope of the rule.

The court say, on page 385: “We find the English rule to be, that courts of equity upon the principle that the jus disponendi is an incident to the absolute ownership of property, will charge the separate estate of a married woman with the payment of debts arising upon her general engagements, whether verbal or in writing, when her intention so to charge them is either expressed or implied.”

Following this is the case of Jenz v. Gugel, 26 O. St., 527, in which the court hold that section 28 of the civil code, as amended March 30, 1874, was not intended to enlarge or vary the liabilities of a married woman, but merely to change the form of the remedy,” and that “ no recovery can be had against a married woman upon her promissory note, whether executed before or after the date of said amendatory act, unless it appear that she has separate property subject to be charged therewith.”

In Avery v. Vansickle, 35 O. St., 270, it was held that in proceedings to subject the estate of a married woman to the payment of a promissory note executed by her, neither party is entitled to demand a trial by jury; that in an action to foreclose a mortgage executed by husband and wife to secure the payment of the wife’s promissory note, constitutes no bar to a subsequent action to subject the separate estate of the wife to the payment of a deficiency arising upon the sale of the property mortgaged.

In Williams v. Urmston, 35 O.

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1 Ohio C.C. 408, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stagge-v-nichols-ohiocirct-1886.