Verdier v. Hyrne

35 S.C.L. 463
CourtSupreme Court of South Carolina
DecidedJanuary 15, 1850
StatusPublished

This text of 35 S.C.L. 463 (Verdier v. Hyrne) is published on Counsel Stack Legal Research, covering Supreme Court of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Verdier v. Hyrne, 35 S.C.L. 463 (S.C. 1850).

Opinions

The Court of Appeals ordered the case up to the Court of Errors, for their adjudication of the question made by the first ground taken for a new trial, and that Court delivered the following opinion.

Curia, per Evans, J.

All the authorities concur that the marital rights of the, husband attach to all the wife’s personal estate in possession, sui juris. So, also, where the wife has an immediate right of possession in severalty to a chattel interest, it becomes the husband’s; on the principle that the right of property draws to it the possession. The same consequences follow where the wife’s title is undisputed, and the chattel is in possession of another, holding under and for her.

But this case requires us to go farther, and to say that where the wife is jointly entitled with another, there the marital right of the husband attached, although the right of the [465]*465wife was disputed, and no partition was made in the wife’s life time, so as to vest in. actual possession every part of the joint estate in severalty. .

Can the affirmative of this proposition be maintained ? If it can, then Verdier is entitled to retain his verdict. I do no.t find any English authority bearing directly on the subject. The reason probably is, that at common law, there was no process whereby joint owners could be compelled- to make partition. The parties -must either continue to hold jointly, or voluntarily make partition. Nor have I found any American case, besides our own, hereafter to be noticed, unless the case of Griswold v. Pennyman, an abstract of which I find in the 5 American Common Law Reports, 552, referring to '2 Cowp. R. 564;■ in -that case it is said, the share of personal estate accruing to the wife during coverture, vests, even before distribution, in the husband, absolutely. If the share spoken of (as I should infer from -the words) be the wife’s share under the Statute of distributions, it is clear that it would not be law in this State, for until distribution, the legal estate is in the executor or administrator, and the wife is not entitled -to possession ; and without a right of possession, it is very clear the marital rights do not attach. The distributee has only an equity until partition is -made.-

But it is supposed that this question has -been decided the cases of the Ordinary v. Geiger, and in Burgess v. Heape, and in other cases which have followed. I am free •to admit, that there are dicta .in some of those cases, assume the doctrine here contended for. But the cases (at least the early ones, which the' subsequent cases profess-to follow,) I am entirely satisfied, were not decided on that principle ; at least it is very clear they might have been decided on other very clear and independent grounds. The case of the Ordinary v. Geiger arose under the following ciroum-•stances: A, by deed, gave certain negroes to four persons; one of them, Dorothy, married Geiger ; one of the negroes, oh, the marriage, went into Geiger’s’possession, but without any formal partition, — on his death the question arose, whether his wife’s share should have been put in the-inventory of his estate? and it was so decided. Now it does not appear with clearness, whether the contest reláted to the negro in his possession, or to his wife’s share in the whole of-the negroes; . but I think it is very clear that the -negro which had been ■ delivered up to Geiger, was alone in question. If it,related to all, and the Court decided, on the ground supposed, that the possession of one joint tenant would suffice to vest the share of another joint tenant in her husband, then it would have been wholly immaterial whether Geiger had had any possession, or there'had been an informal partition. All we know of this case is from Judge Brevard’s Reports.; it is found in a [466]*466note in 2 Nott and McC. 151, but it is there copied from Bre-yard’s Reports then in manuscript. The reporter was one of the four Judges who decided the case. In a note by the reporter, there are two queries: 1st. whether it would have varied the case if it had been proved that the right of the donees to the negroes had been disputed? 2, Did the undivided fart of Dorothy pass to her husband by the marriage ? Why should this quere be put, if the Court had so decided? These notes show very clearly that the learned Judge did not cousider that that case had decided that Dorothy’s undivided interest passed to her husband ; and confirms what I think manifest, that the Court decided on the ground that a partial but informal division had been made, upon which the marital rights of Geiger had attached, because he had a possession in severalty. The first quere conclusively shows that he did not consider that case as deciding that the marital rights attached on any property where the wife’s title was disputed. The most that fian be said to have been decided in that case is, that-where the other joint owners recognize the right of the husband, and admit him into a participation, by giving up to him a part of the property, this was a reduction into actual possession, so as to vest the negro in him jure mariti. The next case was Burgess v. Heape. In that •case, by some legal process, "certain negroes, the property of .the defendant, Heape, and of his sister, Mrs. Burgess, had ■been recovered. The right was, then, clear and established. All that could be necessary to confirm the right of the husband, was a reduction into possession. The negroes were delivered up to Heape. The husband, alone, had a right to receive his wife’s share. A delivery to Heape of the whole, was a delivery to him and Burgess, and his possession was not as joint tenant with his sister, Mrs. Burgess, but as a joint tenant with her husband, who, alone, was entitled to receive her share. It is like (in most respects) a gift made to a wife during coverture,jointly with another. In such case the husband would be entitled, on the principle that a gift to the wife is a direct gift to the husband, and the receipt and possession -of the other joint tenant, would be the possession of himself and the husband. In Burgess v. Heape the Court refer to Geiger’s case as authority for the principle that the possession of Heape was such a possession of his sister, Mrs. Burgess, as to vest her share in the husband. But it was clear the. ■complainants were the only persons entitled to Mrs. Heape’s half of the negroes. Justice was on their side, and the Court was struggling to prevent the defendant from cheating his sister’s husband and child, as would have been the effect of dismissing the bill, because there had been no administration on Mrs. Burgess’s estate. In that case the Court discuss the question, and I am inclined to think the bill might be retain[467]*467ed, although no administration had been granted, as all the parties in interest were before the Court. If it had been t clear that Geiger’s case had decided the principle supposed, it was wholly unnecessary to discuss the other question.

The same dictum is enunciated in Pickett v. Barber; but it was not a point in the case; so also in Verdier v. Verdier. There the question was, whether actual partition had been made by the executor, and that question is extensively dis-1 cussed, but it would have been wholly immaterial, if the possession of a co-tenant was alone sufficient to vest the wife’s undivided share in her husband. There are other cases in which, incidentally, the same doctrine is enunciated, as in

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Bluebook (online)
35 S.C.L. 463, Counsel Stack Legal Research, https://law.counselstack.com/opinion/verdier-v-hyrne-sc-1850.