State v. Philpot

1 Dudley Rep. 46
CourtRichmond Superior Court, Ga.
DecidedJuly 15, 1831
StatusPublished

This text of 1 Dudley Rep. 46 (State v. Philpot) is published on Counsel Stack Legal Research, covering Richmond Superior Court, Ga. primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Philpot, 1 Dudley Rep. 46 (Ga. Super. Ct. 1831).

Opinion

A motion for Philpot’s discharge was made, argued and overruled at a former term upon a slate of facts precisely such as now exists. The court is again moved in this matter upon grounds not then assumed, and is prayed to reconsider its decision then pronounced. Advisement has been had upon every question raised by'the counsel for the movant, and the whole case attentively considered, and the decision of the court will now be pronounced upon each distinct ground on which counsel have rested the motion.

It is contended that the writ of habeas corpus for the disobedience of which Philpot has been attached, is illegal and void, and that the writ, and every proceeding under it should be set aside by the court. Two causes have been assigned against the legality of the writ, and these form the first and second grounds in the motion.

The first cause is its irregularity. The first ground in the written motion submitted is “ Because the habeas corpus by virtue of which the said John N. Philpot was brought before the court, issued illegally in this, that it issued without an affidavit to support it,” though other matters besides the want of an affidavit were insisted on in argument. The particulars arc three, in which the irregularity is said to consist. 1st. The petition is not by the guardian of the boy, James. 2d, The boy’s name is not mentioned in the writ. 3d, Want of an affidavit. The first of these is no irregularity. Tt is not necessary there should exist any particular legal relation between the petitioner and person for whose benefit the writ is awarded. The person imprisoned or illegally detained, may himself petition or complain, or any other person may do it for him. .Nor is the omission of the boy’s name an irregularity. It. can be considered but as a vagueness or uncertainty in the writ, which cannot affect its validity, if enough appear to indicate the person intended. But if it be an irregularity, we shall see whether it have not been waived. An irregularity is the non-conformity to some settled rule of proceeding, by either omitting to do something that is necessary, or doing it at an unseasonable time, or in an improper manner. If the verification of the facts contained in the petition for habeas corpus be something necessary to the attainment of the writ, then its omission is an irregularity.

The writ before the court is a habeas corpus ad subjicien-dum ; at common law, and nearly a century ago the Judges of England gave it. as their unanimous opinion that such a [47]*47writ ought not to issue of course, but upon probable cause supported by affidavit, which has been the regular practice since. But though the writ ought not to issue regularly without affidavit, is the affidavit therefore an essential part of the writ ? The case of the Lady Leigh, cited in 3 Bac. Abr. 5. shows that it is not. In that case no fact was sworn to, but that the Lady Leigh had complained in a letter to her yet the court declared the writ should go to enable her to make oath to the matter complained of, and exhibited articles against her husband : and further, that the Lord Leigh, though a Peer, should be attached if he refused obedience to the writ, However, though the affidavit be not of the essence of the writ, it will never be dispensed with, except in cases of great emer, gency, and the omission will be adjudged an irregularity. We will consider how far this irregularity affects the present case,

irao, was given freedom against and nothing i0l£no other case of the de¿f'Jj’*® however illegal.’ Tho writ of Ah evasio^áñcT' ^re-corpus is a con-persisted 7a, the imprisonment y U'uij. he Pe!¡j’ writ, or show» 1-’m,Pos-

In Tidd’s Practice, 435, the rule of law on this subject is stated to be “ that whenever proceedings are irregular, court on motion will set them aside, provided the application fer that purpose be made in the first instance ; for in all cases of irregularity, the party should apply to the court as ear-]y as possible; and if he either proceed himself after discovering the irregularity, or lie by and suffer the other par-tv to proceed, the court will not assist him.” The language of the court m the case oí Pearson and Kawhngs, 1 East, 77, is clear and very strong. It is the universal tice of the court, that where there has been an irregularity, if the party overlook it and take subsequent steps in the cause, he cannot afterwards revert back to the irregularity and object to it. Justice requires that that rule should be general in its operation, having in view the advancement of right. And however we may be inclined to favor persons in the situation of the defendant, yet we must opt go the length of breaking in upon the general practice of the court.” The same doctrine is held in the cast? of D’Argent and Vivant, 1 East, 330. ‘‘ A defendant may waive irregularity, and is considered as having done so by submitting to the process, instead of taking steps to avail himself of the irregularity, which ought always to be done in the first instance.” See also Fox and Money, 1 B. & P. 250. Davis and Owen, ib. 342. This rule is applicable, however, only to cases of mere irregularity. It is different where there is a complete defect in the proceedings. The former may be waived, but not the latter. Goodwin and Parry, 4 T. R. 517. Hussey and Wilson, 5 T. R. 254. Stevenson v. Danvers, 2 B. & P. 110.

The distinction is then plainly this, that where that is wanting, without which the whole proceedings, are void, no subsequent steps will cure the defects. It is radical. But if that be wanting which will merely render the proceedings voidable, it may be waived by subsequent steps. The case of the [48]*48Lady Leigh before referred to. proves that the verification of the facts contained iri tiie petition forms no part of the process of habeas corpus; for in her case the writ was ordered to go, as well that she might have an opportunity of swearing to the facts as of exhibiting articles against her husband. The affidavit is not, as in bail cases, a part of the process, but is only a preliminary measure in attainment of the process, which is the writ of habeas corpus itself, and serves no other purpose than to convince the mind of the judge that the writ should issue, and to prevent its being abused and made the instrument of vexation. What particular showing was made to the justice who issued this writ, beyond that contained in the petition, does not appear ; no affidavit is annexed. He, however, exercising the power vested in him by law, awarded the writ, and much proceeding has been had upon it, though the petioner has not yet sworn to the facts in the petition. Let us look to these proceedings or subsequent steps, and see if enough has not been disclosed by Philpot himself to convince the court of the propriety and even necessity of issuing the writ in the first instance, and to amount to a waiver of any irregularity.

The first step taken by Philpot is his appearance in obedience to the writ, and moving to adjourn the return to a future day, to enable him to produce the boy, whom he admitted to be in a certain place, which motion, (the petitioner consenting) is allowed.

The next isjfiling his return, in which no exception is taken, for want of an affidavit, nor averment made that the boy is a slave, though it is insisted that negroes or persons of color have no right to the writ. Then an argument upon the sufficiency of the return, which was adjudged evasive and insufficient, and an attachment ordered. Arid lastly, a motion for discharge from the attachment, on two grounds. 1.

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Bluebook (online)
1 Dudley Rep. 46, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-philpot-gasuperctrichm-1831.