Whitehurst v. Taylor

4 Balt. C. Rep. 444
CourtBaltimore City Circuit Court
DecidedFebruary 15, 1926
StatusPublished

This text of 4 Balt. C. Rep. 444 (Whitehurst v. Taylor) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Whitehurst v. Taylor, 4 Balt. C. Rep. 444 (Md. Super. Ct. 1926).

Opinion

SORTER, J.

Very briefly, the facts in this case are that Mr. Charles E. Whitehurst, a resident of Baltimore City, died intestate, leaving a large estate. The complainant, Claire J. Ulrich Whitehurst, claiming to be his widow, brought this proceeding for the purpose of having declared void an instrument in writing by which she conveyed and quit-claimed any interest in ills estate she may have had, to the defendant, the mother of the decedent. As the entire estate has been distributed to the defendant, the bill prays for a decree against her for one-half the estate thus distributed —less the sum of eleven thousand dollars paid complainant as the consideration for the assignment. The complainant charges fraud on the part of the defendant in procuring from her this assignment. She further asks the Court to judicially decree her marriage to Mr. Whitehurst to be valid. The defendant filed a general demurrer to the whole bill of complaint setting up four grounds.

1.

The first ground of demurrer invokes the equitable doctrine of restitution, by stating that tlie complainant does not offer to return the consideration for the assignment, which in tlie bill is set at eleven thousand dollars and in the demurrer at sixteen thousand dollars. The general rule relating to the right of rescission and cancellation of instruments procured by fraud, is that these rights are founded upon equitable principles and the injured party may not require the return of what has been obtained from him by deceit, until he has in turn restored, or offered to restore to the limit of possibility, what of value was received by him from the wrongdoer. This is the rule as stated in Steigler vs. Eureka Life Insurance Co., 146 Md., at page 643, with other cases therein cited. The exception to this rule of restitution is stated in Willis-ton on Contracts, Sec. 1530, as follows : “And one who attempts to rescind a transaction on the ground of fraud, mistake or otherwise, is not bound to restore that which he has received by virtue thereof, when in any event lie is entitled to retain it as indisputably his own no matter what may bo the fate of his effort to rescind the transaction.”

See also Pomeroy’s Equitable Remedies, Vol. 2, Sec. 688, and cases cited.

In the case of Hall vs. Hall, 147 Md. 184, a family settlement was entered into between the widow of the decedent; and certain members of the family. The widow having later discovered that her consent to the agreement which reduced her share from one-third to ore-fifth had been procured by fraud sought to set aside. In the meanwhile she had received from the administrator “a check on account of the agreement.” It was held that her right; to rescind did not; require that she should return the check as it could he accounted for by a credit upon her share of the estate. This case may be distinguishable from the present one upon this fact, which is, that the money she received was estate money to which she. was undoubtedly entitled, but there is nevertheless underlying the decision the idea that it would be a vain and idle ceremony to return to the estate that which she would immediately receive together with a much larger sum. The reason for the rule of restitution is that if the plaintiff succeeds in his efforts to obtain a cancellation, and this would leave him with something which equitably belongs to the other person, that something must lie paid or tendered as a prerequisite to his suit. In the case, at bar, if the plaintiff succeeds in avoiding the assignment it still leaves the defendant with property nearly nine times in value belonging to the plaintiff. This is of course provided she is able to establish the validity of the marriage, a matter which will be later considered. Counsel for defendant relies strongly upon the case of Hite vs. Mercantile Trust Co., 156 Cal. 765. In that case there was an agreement between husband and wife by which the wife received a substantial sum [446]*446directly from him and released him from any interest in his property or his estate. This was later followed by a divorce between them. Upon the death of the husband, the former wife fild a bill against the administrators for two purposes, viz: avoiding the agreement and nullifying the divorce. As to the latter relief the Court held that the right to nullify a divorce was a personal action and died with the husband. As to the right to rescind the Court held that restitution would be a prerequisite. The reason for the application of this rule was that the Court held that she would not ipso facto be entitled to share as a widow. The Court said “The question would be merely reopened for further investigation of her marital status towards Hite, of the nature and amount of his estate, and the effect of his will which gives nothing to the plaintiff. She may not succeed m obtaining any part of the estate even if she should succeed m the present suit."

The bill sets up in minute detail the acts constituting the alleged marriage ceremony and to arrive at a just conclusion as to whether restitution is necessary or not an inescapable legal problem is offered as to whether this foreign marriage is so pleaded as to compel the admission by the demurrer that it is a valid and binding marriage. The marriage is pleaded in the following manner. It is alleged that the parties agreed to become married at a future date which was settled upon. Correspondence between them took place and subsequently a form of marriage ceremony took place, consisting of at least present agreements in the presence of a witness, the details of which are minutely set forth. It is further stated that following said marriage and as a result thereof cohabitation took place and the decedent introduced the complainant as his wife to some of their mutual friends. The marriage took place in the State of New York and the following allegation is made, viz: “That under the law then in force in the State of New York where said marriage was thus celebrated, both by their agreement and by the ceremony thus followed, the same was in all respects lawful, valid and binding and did constitute said parties husband and wife, as fully and completely as though performed or celebrated by a priest or by any civil officer or official, or by any' other person or in any other manner.”

As to whether the foreign law is sufficiently pleaded in this case is a question far from being free from difficulty. In the case of Furlong vs. German-American Press, 189 S. W. 385, Missouri, 1916, where the action was one of libel and the libel consisted of charging the plaintiff with kidnapping and the further allegation was made and plaintiff states that the crime of kidnapping in the State of California is a felony and punishable toy imprisonment in States prison for a term of from one to ten years, the -Court held on demurrer “no statute or other law of California or other State adopting the common law or directly making kidnapping an offense is properly pleaded. The bald allegation that kidnapping is a felony under California is insufficient.”

In McLeod vs. Railroad Company, 58 Vt., which was a negligence case arising out of an accident in Quebec, a demurrer to the declaration was sustained. The Court said “It is essential that the foreign law from which the alleged duty springs should be so fully stated.”

Both of these cases will be found referred to in a note in the Harvard Law Review, January issue, 1926, page 378.

In other decisions it is stated that foreign law thus pleaded is a pleading of fact and not a conclusion of law. Hanley vs. Donoghue, 116 U. S. 1

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hanley v. Donoghue
116 U.S. 1 (Supreme Court, 1885)
Finney v. Guy
189 U.S. 335 (Supreme Court, 1903)
Hite v. Mercantile Tr. Co. of S.F.
106 P. 102 (California Supreme Court, 1909)
Prince De Bearn v. Winans
74 A. 626 (Court of Appeals of Maryland, 1909)
Hall v. Hall
127 A. 858 (Court of Appeals of Maryland, 1925)
De Crette v. Mohler
127 A. 639 (Court of Appeals of Maryland, 1925)
Colonial Trust Co. v. Fidelity & Deposit Co.
123 A. 187 (Court of Appeals of Maryland, 1923)
Malkus v. Richardson
92 A. 474 (Court of Appeals of Maryland, 1914)
Bayley v. Bayley
141 A.D. 243 (Appellate Division of the Supreme Court of New York, 1910)
Edwards v. Schillinger
91 N.E. 1048 (Illinois Supreme Court, 1910)
Smith v. Stockbridge
39 Md. 640 (Court of Appeals of Maryland, 1874)
Zollickoffer v. Seth
44 Md. 359 (Court of Appeals of Maryland, 1876)
Gavin v. Carling
55 Md. 530 (Court of Appeals of Maryland, 1881)
Baltimore Retort & Fire Brick Co. v. Mali
3 A. 286 (Court of Appeals of Maryland, 1886)
Shriver v. State ex rel. Reister
4 A. 679 (Court of Appeals of Maryland, 1886)
Myers v. Safe Deposit & Trust Co.
21 A. 58 (Court of Appeals of Maryland, 1891)
Garrison v. Hill
31 A. 794 (Court of Appeals of Maryland, 1895)

Cite This Page — Counsel Stack

Bluebook (online)
4 Balt. C. Rep. 444, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitehurst-v-taylor-mdcirctctbalt-1926.