Weakley v. Cockrill

2 Tenn. Ch. R. 316
CourtCourt of Appeals of Tennessee
DecidedApril 15, 1875
StatusPublished

This text of 2 Tenn. Ch. R. 316 (Weakley v. Cockrill) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Weakley v. Cockrill, 2 Tenn. Ch. R. 316 (Tenn. Ct. App. 1875).

Opinion

The Chancellor:

— The principal question raised by the «demurrer in this case has been discussed with marked ability by the counsel on both sides. That question is, whether a debtor’s right to redeem his land, within two years after sale by execution, can be subjected, by bill in this court, to the satisfaction of the residue of the judgment under the execution on which the legal interest of the debtor in the land had been sold, and bid in by the judgment creditor. The facts are that the complainant, having .a judgment for several thousand dollars against the defendant, causes execution to issue and be levied’ on the land, and at the sale bids it off at $25, and then, upon a return of [317]*317nulla bona as to the residue of the execution, hies this bill to subject to the satisfaction of that residue the defendant’» right to redeem. The defendant has demurred to this bill», assigning as causes, first, that the interest of the debtor is. not such as to fall within the provision of the Code, § 4282, et seq., and, secondly, if it be, that the Code, § 2124, et seq., gives the debtor two years to redeem, and that the right claimed to acquire a lien by a bill in this court is-incompatible with the right to redeem. The argument involves the consideration ,of the nature of the debtor’s-interest in the land after sale, and also whether, if it be-such as could be subjected by the creditor in this court, the-exercise of the jurisdiction is consistent with the policy of the redemption laws. Both branches of the argument present novel and interesting questions for discussion, by-no means free from difficulty.

The act of 1820, ch. 11, was the first act of the legislature in this state providing for the redemption of real estate after a sale by execution, and it has formed the basis of our redemption laws ever since. In Hawkins v. Jamison, M. & Y. 83, Judge Crabb took occasion to say that the act Avas very inartificially worded, and that it was extremely difficult to ascertain what, in some respects, was the intention of the legislature. This language has been repeated in substance in subsequent cases, without the court undertaking to construe the act as a whole, leaving each case to turn upon its own facts. The result has been that, while-there is little conflict in the decisions, the reasoning on-which the decisions rest, and the principles which underlie-them, are not in strict accord.

In the earliest case already cited Judge Crabb says that the relations of the debtor and purchaser after sale cannot be likened to those of mortgagor and mortgagee, or pledgor and pledgee. “ The fact is,” he adds, “ the act in question is sui generis, and the rights arising under it of a peculiar-nature. The purchaser is the legal owner of the property sold under execution, by virtue of the deed from the sheriff, [318]*318as heretofore, subject to the equitable right of the debtor to reclaim, or repurchase it, upon the terms specified in the act.”

One line of our decisions has taken up the first idea here expressed, that the purchaser is the legal owner of the land, and has carried it out to all its logical sequences. The right of the debtor, in this view, is a mere liberty to repurchase, and the condition must be strictly performed within the time limited, or it is gone forever. A tender of banknotes was, therefore, held not to give the debtor any equity under the statute. Lowry v. McGhee, 8 Yerg. 245. And, even if a good tender has been made, the money must be brought into court upon bill filed. Simmons v. Marable, 11 Humph. 436. The purchaser in possession is, moreover, not liable for waste if the land is redeemed. Kannon v. Pillow, 7 Humph. 281, overruling the previous case, holding directly the contrary, of Sherats v. Firestone, 7 Humph. 293. Hollowing out the same train of reasoning, an act extending the time of redemption on account of the anarchy of the late civil war, after the expiration of the two years, was held unconstitutional and void. Reynolds v. Baker, 6 Coldw. 221. The learned judge who delivers the opinion of the court in this case says, arguendo: “ The right of the debtor to redeem is not an equity of redemption in the sense of the law of mortgage. It is not an estate or interest in the land. The whole interest is vested in the purchaser by the sale. The right of the debtor is strictly a right of repurchase.” And yet the same eminent judge, in the progress of his opinion, concedes that, if the redemption in time is prevented by the fraud of the purchaser ( Guinn v. Locke, 1 Head. 110), or by an agreement, even in parol, to extend the period (Haywood v. Ensley, 8 Humph. 460), or perhaps by duress, imprisonment, or overwhelming power, the right may be saved.

On the other hand, there is a longer line of decisions taking up Judge Crabb’s second suggestion of the equitable right” of the debtor, and carrying it out to its logical [319]*319results. In Elliott v. Patton, 4 Yerg. 10, the very next -case which came before the courts, it was expressly held that the l’ight to redeem after sale, which the learned judge who delivers the opinion calls the “ equity of redemption,” descends, upon the debtor’s death, to his heirs, and cannot be reached by judgment creditors until the plea of fully .administered is found in favor of the personal representative. The right of a judgment creditor of the ancestor to redeem under the statute is lost, because the right of the judgment debtor, upon which the creditor’s right is thus made to depend, had descended as realty to his heirs. In Pillow v. Langtree, 5 Humph. 389, in strict accord with this view, the right to redeem was held to pass, under the bankrupt law of congress then in force, to the assignee in bankruptcy, under a provision of the law “that all the property and rights of property, of every name and nature, and whether real, personal, or mixed,” shall, by operation of law, vest in the assignee. And the same conclusion has been reached under the present bankrupt law. Toombs v. Palmer, 4 Heisk. 331. In both cases the rights of the creditors of the debtor to redeem were considered as cut off, because the debtor’s right had passed, as property, to “the assignee. Following this lead, it was held in Jones v. Planters’ Bank, 5 Humph. 619, that a conveyance, by the debtor, of the land before the execution sale, and, in Kennedy v. Howard, 6 Humph. 64, a similar conveyance of the laud after the execution sale, would vest the grantee “ with “the equitable estate of the defendant in the execution.” In Hepburn v. Kerr, 9 Humph. 726, 730, these rulings were reaffirmed. And in Huffacre v. Bowman, 4 Sneed, 89, the Tight of the judgment debtor to assign his equity of redemption was considered as a settled question, and the court add : “And if this right be once fairly extinguished in the judgment debtor, can it be held to exist in favor of his creditors ? To affirm that it might continue to exist in favor of creditors, though extinct as to the debtor, through whose Tight the equity of the creditors is to be wrought out, would [320]*320seem to be absurd.” And so, accordingly, it was considered in Birdwell v. Cain, 1 Coldw. 301; Graves v. McFarlane, 2 Coldw. 167; and Toombs v. Palmer, 4 Heisk. 331. Judge Reese had long before, in Pillow v. Langtree, 5 Humph.

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Related

Miller v. . Lewis
4 N.Y. 554 (New York Court of Appeals, 1851)
Farnham v. Campbell
10 Paige Ch. 598 (New York Court of Chancery, 1844)
Toombs v. Palmer
51 Tenn. 331 (Tennessee Supreme Court, 1871)

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Bluebook (online)
2 Tenn. Ch. R. 316, Counsel Stack Legal Research, https://law.counselstack.com/opinion/weakley-v-cockrill-tennctapp-1875.