Watson v. Kennedy

22 S.C. Eq. 1
CourtCourt of Appeals of South Carolina
DecidedMay 15, 1849
StatusPublished

This text of 22 S.C. Eq. 1 (Watson v. Kennedy) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watson v. Kennedy, 22 S.C. Eq. 1 (S.C. Ct. App. 1849).

Opinions

Curia, per

DaugaN, Ch.

The Chancellor who heard this case, in defining the law applicable to the subject, holds the following language:

“ When a father, on the marriage of a son, delivers to him a slave, or permits the slave to go home with him, or sends the slave to him, it is prima facie evidence of a gift; but the presumption may be rebutted by proof of the circumstances under which the parent gave possession to the child : and for this purpose the declarations of the parent, when the delivery is made, are admissible, to ascertain whether a gift or loan was intended, although made in the absence of the child.” The whole of the foregoing proposition is, in my opinion, perfectly unexceptionable, save that part which asserts that the declarations of the parent, made in the absence of the child, are admissible to ascertain whether a gift or loan was intended. The language in which the proposition is stated, implies that such declarations would be admissible, to ascertain whether a gift or loan was intended, although the child should not be proved to have known that the declarations were made, which qualified his possession into a [7]*7loan. It might not be very material whether the qualifying declarations should be made to the child in person, or to an-( other who, in a very short period afterwards, should comma-nicate to the child the qualifying conditions annexed by the declarations of the parent to the transfer of possession. But, in my opinion, the declarations of the parent, made in the absence of the child, though accompanying the transfer, and though competent, as a part of the res gestee, to be offered in evidence, should be utterly unavailable in qualifying the transaction into a loan instead of a gift, unless those qualifying declarations are shewn to have been communicated immediately to the child, or brought home to his knowledge within a reasonably early period afterwards. And this I take to be the settled law of the land.
x N_ & McC_ 221. 4 McC. R. 251. McMul. Eq. 115- in.&McC. 224- 1 Rich. Eq. 310'

In Banks v. Hatton it is indeed said that such declarations are competent. There, the father called on his other son and family to witness that he sent the negroes as a loan. But, notwithstanding the accompanying declarations of the father, the gift was established, although it was proved that the son had said he had been offered a great price for the negroes, and if they liad been his, he would have taken it; and to another witness, had acknowledged that the negroes belonged to his father. Thus it appears that the very case from which the objectionable principle here commented on has been deduced, goes far to establish a contrary doctrine.

In McCluney v. Lockhart Judge Colcock says, “the and well established doctrine is, that the presumption of a gift may arise from the circumstance of a parent’s sending a slave to a married child, and suffering it to remain in possession of such child, without any express stipulation on the subject.”

In White v. Palmer the negroes had been suffered to go into the possession of the son-in-law on his marriage, .and, shortly afterwards, the father-in-law executed a deed, by which the negroes were intended to be settled upon his daughter. It was held that the deed was void as to creditors, unless its execution had been with the consent and privity of the husband at the time, or accepted by him. The remark of Judge Nott, in Bradshears v. Blossingame, that conditions annexed to these marriage gifts were not to be encouraged, was quoted with approbation by the Chancellor who delivered the decree of the Court. And in the course of his remarks he says, “ I think it should be clearly shewn, that it was the understanding of all parties, and especially of the husband, that it was meant as a loan and not a gift.”

In Eddings v. Whaley, Chancellor Dunkin, in his decree, holds the following language on the subject. “The legal effect,” says he, “of the possession, under the circumstances, is to confer title. The defendant must prove that it was a [8]*8loan. It is not enough, that he intended in his own mind to reserve a control over the properly. If the possession of the plaintiff was such as, -prima facie, completed his title, no mental reservation on the part of the defendant could defeat this legal consequence. There must have been some express stipulation at the time, distinctly understood by both parties, in order to give effect to such an intention. It is not á question of what he intended, but what he actually did.” The decree of the Court of Appeals, by Chancellor Johnson, affirming the circuit decree, is of a corresponding tenor. I quote his concluding remarks — “where nothing but an absolute gift is intended, nothing but delivery is necessary. If it is intended to qualify it, the parent ought to, and I think would, express it. He could not be so unjust to his child as to raise expectations, with the secret intention of mortifying him by defeating them.”

It seems to me that the parent’s annexing a condition to the delivery oí possession, in the absence of the child, in the presence of a third person who may never communicate it to the child, is in no particular more just or reasonable than a mental reservation. The act of transferring the possession, in legal effect amounts, prima facie, to a gift. In delivering possession of the negro to his son, or son-in-law, as the case may be, in the understanding of the law, he says, “ I give you this negro.” And, aside, he says to some third person, his own wife perhaps, or some other member of his family, I do not give but I lend.” This is unjust to the child, is calculated to raise illusory expectations, and is breaking the word of promise, both to the ear and the sense. These secret conditions are intended only to be used on certain contingencies. If the daughter dies, or the son or son-in-law becomes a bankrupt, or there is strife and misunderstanding between the parent and child, the gift is reclaimed. Otherwise, the possession of the child is scarcely ever sought to be disturbed.

In the case, however, now before the Court for its judgment, the discussion foregoing may be considered rather in the nature of an abstract inquiry, and is intended only to prevent misconception of what might appear an acquiesence in an erroneous exposition of an important principle of law ,• an exposition tending to unsettle, in my judgment, former adjudications. This court is unanimously satisfied with the result of the Chancellor’s decree in reference to the negroes Charlotte and her children, claimed by the defendants, the creditors of Joseph Kennedy, to have been given as a marriage gift to his wife by her mother, Harriet Watson, the complainant. The claim to these negroes is advanced in behalf of the creditors of the alleged donees, and, as usual in such cases, the alleged donees are presented as witnesses against [9]*9the gift. Accordingly, Mr. and Mrs. Kennedy, and another daughter of the complainant, (Mrs. Stith) making quite a family group, all assail the transaction as being a gift. The two ladies do not testily to circumstances deemed very material, being, mostly, declarations of Mrs.

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22 S.C. Eq. 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watson-v-kennedy-scctapp-1849.