United States Mortgage & Tr. Co. v. Anderson

20 Ohio C.C. Dec. 553, 11 Ohio C.C. (n.s.) 246
CourtLucas Circuit Court
DecidedMarch 10, 1908
StatusPublished

This text of 20 Ohio C.C. Dec. 553 (United States Mortgage & Tr. Co. v. Anderson) is published on Counsel Stack Legal Research, covering Lucas Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States Mortgage & Tr. Co. v. Anderson, 20 Ohio C.C. Dec. 553, 11 Ohio C.C. (n.s.) 246 (Ohio Super. Ct. 1908).

Opinion

WILDMAN, J.

The demurrer as presented to us is to the petition of The United States Mortgage and Trust Company, the plaintiff, filed by the defendant,'Peter Anderson, in the court below and re-urged here.

The allegation of the petition as to the reasons for making him a party defendant is as follows: “Plaintiff further says that the defendant, Peter Anderson, claims to be the owner in fee simple of said premises.” And just before the prayer it is said “The plaintiff therefore asks that they” (certain defendants) “be required to answer and set forth their respective claims or be forever barred.” It,may be a question whether this prayer refers to the defendants immediately before named, or whether it includes with the other defendants, Peter Anderson. All are named in one paragraph, and as the statement in regard to the other defendants is similar to that with regard to Anderson, my own judgment is that this clause is intended to refer to all defendants who are so brought in.

In Bates, PI. & Pr., and in the Kansas cases which he cites, it is indicated that an averment of this kind is hardly sufficient in some [554]*554jurisdictions, or at least in those to which reference is made by Bates, without some further averment disputing the validity of the claims asserted by the parties so brought in. But in the ease of Winemiller v. Laughlin, 51 Ohio St. 421 [38 N. E. Rep. 111], our Supreme Court makes a little more liberal interpretation of Rev. Stat. 5006 (Lan. 8521). It will be remembered that that section provides that any person may be made a party who has or claims an interest in the con-’ troversy, and no special requirement is made in the statute as to the averments that are to be made as to the asserted rights of such claimants. In Winemiller v. Laughlin, supra, it was held in the syllabus, second paragraph, that

‘ ‘ The plaintiff in. an action to foreclose a mortgage, is not required to set forth either the nature of, or the facts constituting the claim ■of another lien holder, in order to bar the latter by a decree against his claim if he should fail to answer. If for that purpose anything more is required than to make him a party and serve him with legal process, it will be sufficient for the petition to state that such defendant claims some interest in the mortgaged premises, and advises him that his claim or lien will be barred if he fails to appear and disclose it.”

It will be noticed that there is an implication here that possibly it will not be necessary to say anything about his claim; that it may be necessary only to make him a party by summons, thereby giving him an opportunity to assert his claim by pleading it; in other words, that it may suffice to serve notice upon him that there is a suit in which the property in which he claims to have an interest is to be made the subject of a controversy and possible sale. But whether that is or is not permissible, the Supreme Court has definitely determined by this decision that it is not necessary to do moré than say in the petition that he has or claims an interest in the controversy, advising him that it will be barred if he fails to appear and disclose it and then serve him with summons, giving him an opportunity to assert his rights and have them litigated.

We are .unanimous in the opinion derived from an examination of the numerous authorities cited, that the strong current of adjudications outside of our own state, is in support of the contention that prior encumbrancers or claimants other than such as derive their titles or interests from the mortgagor of the mortgage which is sought to be foreclosed are neither necessary nor proper parties in a suit of this kind, and the important query with us, and the one to which we have devoted the most of our attention, is as to whether that rule prevails in Ohio, whether it is the practice which has been adopted here, [555]*555and whether it is the rule best supported'by the'adjudications and the statutes of our .own state.

In Whittaker’s Annotated Code, in his annotation of Sec. 5006 [Lan. 8521], on page 106 (bottom paging), are references to some of the same authorities which have been cited in argument, and. also to Mr. Bliss’ work on Code Pleading, to which in our somewhat hurried examination of the question we have not had accessf He cites Bliss, Code Plead. Secs. 100, 101, in support of the proposition that in Ohio •such prior encumbrancers or outstanding claimants are proper parties, whether or not they are necessary ones.

In 1 Bates, Pl. & Pr. 583, is a discussion of the question very pertinent to the consideration of this demurrer. I read from the edition of 1881 which considered the authorities, or at least a number of them, bearing date prior to that time. There is no essential addition to the discussion of the question in the very recent edition of the same work. On the page to which I have referred, Mr. Bates calls attention to the distinction between necessary and merely proper parties, .and says that that distinction is very clearly shown in foreclosure cases. We have often had occasion to examine the distinction between mandatory and permissive joinder of parties. There are cases where persons must be brought in because they are essential to a determination of the controversy, and others where they may be brought in, in order to permit an adjudication of all controversies respecting claims relating to the same property in the same action.

At the outset it may be said that the law might proceed upon either of two contradictory policies. It might attempt to protect paramount lien holders, against any disturbance of their claims by contests between subsequent mortgagees and persons owning the equities of redemption. It might by like reasoning and upon the same principle decline to embarrass or disturb outstanding claimants by bringing them into the litigation of controversies with which they have no concern. •On the other hand, it' may be the policy of the law to protect purchasers .at judicial sales and to make more convenient the ascertainment of the value of properties sought to be sold. One state may adopt •one policy, and another, another, and in determining which policies have been chosen in the different jurisdictions something may depend upon the nature of the foreclosure proceedings in the various states. In Ohio it necessarily involves a judicial sale, for the proceeds of the property are subjected to the payment of the mortgage claim. Not so in some of the states. In several of them the mortgagee takes .the property without any judicial sale at all.

[556]*556Now, manifestly, in a state where no appraisal and sale are required, a very different rule might apply. Mr. Bates, in further consideration of this question, bases a large part of his reasoning upon the provisions of our statutes as to appraisal of the property and its-sale to a purchaser. Omitting his language on this page until we arrive at Par. 18, we find under the caption, “Prior Encumbrancers,. Whether Proper:”

“The very great authority of Mr. Pomeroy, sections 334 and 342, note 4, is that the incumbrancers whose liens are prior to that of the plaintiff, are in no way affected by the decree of foreclosure or the sale thereunder. Their rights are paramount, and they are neither necessary nor proper parties, and says it is generally so considered except in Iowa, citing a number of authorities, to which may be added Broward v. Hoeg, 15 Fla. 370; Coy v. Downie, 14 Fla.

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Cite This Page — Counsel Stack

Bluebook (online)
20 Ohio C.C. Dec. 553, 11 Ohio C.C. (n.s.) 246, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-mortgage-tr-co-v-anderson-ohcirctlucas-1908.