State v. Gibbs

7 Ohio N.P. 345, 7 Ohio N.P. (n.s.) 345
CourtHuron County Court of Common Pleas
DecidedAugust 17, 1908
StatusPublished

This text of 7 Ohio N.P. 345 (State v. Gibbs) is published on Counsel Stack Legal Research, covering Huron 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
State v. Gibbs, 7 Ohio N.P. 345, 7 Ohio N.P. (n.s.) 345 (Ohio Super. Ct. 1908).

Opinion

Doyle, J.

Heard on demurrers to indictment.

The indictment in this ease purports to charge a crime under Section 30 of “An act to authorize free banking,” passed March 21, 1851 (49 O. L., 41), as amended April 24, 1879 (76 O. L., 72, 74). It was so recognized by counsel in the argument of the issues in this case, and is apparent from the fact that no general criminal statute applying to banking institutions provides penalties for the acts complained of in this indictment, under which this indictment can be brought.

Before discussing any other objections to the indictment 'it should first be determined whether the provisions of Section 30, as amended 76 O. L., 72, are applicable to the defendants. If they are not, then no crime is charged against these defeñdants.

The indictment charges that the accused, being respectively president and vice-president .and both directors of the Ohio Trust Company, with intent to injure and defraud, unlawfully did ab[346]*346stract and willfully misapply certain funds and credits of said the Ohio Trust Company, by unlawfully, willfully and not for any use,'benefit, gain or advantage of said the Ohio Trust Company, converting, applying and conveying said funds and credits to the use, benefit, control, gain and advantage of certain’ persons unknown to the grand jury.

Section 30 of the act in question as amended (R. S., 3821-85), reads as follows:

“Every president, director, cashier, teller, clerk, or agent of any banking company, who shall embezzle, abstract, or willfully misapply any of the moneys, funds, or credits of such company, or shall, without authority from the directors, issue or put forth any certificate of deposit, draw any order or bill of exchange, make any acceptance, assign any notes, bonds, drafts or bills of exchange, mortgage, judgment or decree, or shall make any false entry in .any book, report, or statement of the company, with the intent in either case to injure or defraud the company, or any other company, body politic or corporate, or any individual person, or to deceive any officer of the company, or any agent appointed to inspect the affairs of any banking company in this state, shall be guilty of an offense, and, upon conviction thereof, shall be confined in the penitentiary, at hard labor, not less than one year nor more than ten years. ’ ’

It was put in this form April 24, 1879 (76 O. L., 74). The section as originally enacted read as follows (49 O. L., 41):

“Every president, director, cashier, teller, clerk or agent of any banking company, who shall embezzle, abstract, or willfully misapply any of the moneys, funds, or credits of such company, or shall, without authority from «the directors, -issue or put in circulation any of the notes of such company, or shall put in circulation any bills or notes purporting to be the circulating bills Or notes of such bank, other than those delivered to such bank by the auditor of state, -as provided for by this act, either with or without the authority of the directors; or shall, without such authority, issue or put forth any certificate of deposit, draw any order or bill of exchange, 'make any acceptance, assign any note, bond, draft, bill of exchange, mortgage, judgment or decree, or shall make any false entry on any book, report or statement of the company, with an intent in either case to injure or defraud such company, or to injure or defraud any other company, body corporate or politic, or any individual person, or to [347]*347deceive any officer or agent appointed to inspect -the affairs of any. banting company in the state, shall be guilty of a misdemeanor, and upon conviction thereof, shall be confined in the penitentiary at hard labor, not less than five -nor more than ten years. ’ ’

The indictment does not show nor is it claimed that the Ohio Trust Company was organized under the act of March 21,. 1851 (49 O. L., 41).

If the provisions of Section 30 above noted only apply to banks organized under the provisions of that .act, then this indictment-does not charge facts constituting a crime.

During the early history of our state it was regarded that the principal privilege of a bank was to issue and put in circulation notes which were designed to circulate as currency. This became a great evil -and was met by the act of February 8, 1815 (13 O. L., 152; 2 Chase, 868), which prohibited individuals and companies of individuals from issuing bank notes unless the individual be specially authorized or the company incorporated for that purpose, but these acts did not prevent companies and individuals from receiving deposits, discounting exchange, loaning money and dealing in commercial paper and doing other things which are regarded as a legitimate function of banking institutions today. Again on January 27, 1816 (36 O. L., 101; Swan, 136), by an act to prohibit unauthorized bank paper, and the exercise of banking powers, except by “banks incorporated by a law of this state. ’ ’

From that time until 1845 many special laws were passed incorporating .companies to do a banking business, in which the powers, restrictions, manner of organization, manner of conducting business, obligations and duration of franchise of each of them were set forth. 3 Chase, 2019-2083.

March 7, 1842 (40 O. L., 39), an act was passed which provided regulations to apply to banks thereafter incorporated and was amended February 21, 1843 (41 O. L., 36), by incorporating-several new banks and making them subject to -these regulations. These restrictions not being agreeable to some of the banks which had come in under its provisions, several of them were by act of February 15, 1844 (42 O. L., 19), restored to their original charters.

[348]*348These banks thus authorized by those several acts or charters issued currency based upon the credit and assets of the respective companies. These franchises were eagerly sought and companies ostensibly chartered for other' purposes attempted to so have their powers construed as to permit them to do banking. Legislators carefully scrutinized bilk' granting charters, to ascertain if lurking within the powers granted were any that could be construed into an authority to do banking. Along with many other' reported cases .attention is called to those reported for the December term, 1841, of our Supreme Court—State v. Alexandrian Soc., 11 Ohio, 1; Lougee v. State, 11 Ohio, 68; Bonsal v. State, 11 Ohio, 73; Steedman v. State, 11 Ohio, 82; State v. Library Co., 11 Ohio, 96; and State v. Exporting Co., 11 Ohio, 126, as interesting fragments of the history of banking in Ohio during that period, and as throwing light ,on the causes which induced and circumstances surounding subsequent legislation, on banks -and banking.

Finally to meet the demand for safe banks and for a better currency and to give the business the benefits and sanction of a state supervision over -it the act of February 24, 1845 (43 O. L., 24; Curwen, 1089; S. & C., 117), was passed which provided for incorporating the State Bank and other banking companies. The report of the bank commissioners, July 26, 1842, shows the the necessity. The year 1841 and commencement of 1842 were .marked by the failure of about one-third of the banks of Ohio.

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Cite This Page — Counsel Stack

Bluebook (online)
7 Ohio N.P. 345, 7 Ohio N.P. (n.s.) 345, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-gibbs-ohctcomplhuron-1908.