Whittemore v. Whittemore

2 N.H. 26
CourtSuperior Court of New Hampshire
DecidedApril 15, 1819
StatusPublished
Cited by3 cases

This text of 2 N.H. 26 (Whittemore v. Whittemore) is published on Counsel Stack Legal Research, covering Superior Court of New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Whittemore v. Whittemore, 2 N.H. 26 (N.H. Super. Ct. 1819).

Opinion

Woodbury, J.

In the consideration of this case, it is to be kept in constant remembrance, that the submission was [27]*27not a judicial proceeding, by a rule of court, or by an agreement signed and acknowledged before a magistrate; but by a private contract between the parties. The submission, also, -was not special, bat of all demands, generally.

The first material question concerns the validity of the award. It has been held, that where a submission enumerates the specific subjects referred, and enjoins, that the arbitrators act upon the, premises, and some of the subjects are not acted on, the award is bad. Kyd on Awards 181.— 7 East 81.— Cro. Eliz. 839, Risden vs. Inglet.—14 John. 106.

The reasons seem to be, that a submission, when thus expressed, makes the decision of every item specified a condition precedent to the award; and, also, if not decided, when thus specially enumerated, there must have been such gross neglect, either in the parties or the arbitrators, as ought to avoid the award.

In the present case, however, the submission was not of this character, else, the whole award being void, there would, on the merits, be no bar to a recovery of every thing submitted, unless we adopted the less rigid chancery rule, that, if the omission of some of the subjects specified did not appear injurious to either party, the award should still be binding in respect to those subjects, whose consideration was not omitted. 7 Cranch 171, Davy’s Extors, vs. Faw.

This submission was a general one; and, in such an one it has been held, even at law, that the award is not void, if it embrace all the subjects actually laid before the arbitrators, though other demands existed between the parties, which were not laid before them. Kyd on Aw. 176.—1 Burr. 274.— Cro. Ja. 200, 355.-8 Coke 195.—Cro. El 839.—2 Gallison 77.—Sed. 16 East 58, Mitchell vs. Stavely.

The reasons seem to be, that in such case there is no enumerated item omitted, which, as a condition precedent, was to have been adjudicated ; and though the agreement may in some sense be broken, as all demands are not actually laid before the arbitrators and settled; yet this does not arise from neglect in the arbitrators, who, in a general submission, are of course unacquainted with any demands not [28]*28exhibited. It often happens, too, without neglect in cither of the parties; because the demands, not being specified, some may be omitted by forgetfulness, mistake, or accident; and, indeed, some existing demands may be unknown to the party himself who is interested, as a recent and secret injury to his property by his antagonist; or a right, accrued to legacies in the hands of the latter, or from conditions just happened.

To prevent injustice in such cases and to give redress where one, by craft, conceals a secret cause of action so as to avoid the award afterwards, if not acceptable ; (8 Coke 196, Baspole’s case) the award may well be held good on all subjects actually adjudicated ; and the parties be left to their actions at law for those not adjudicated. But whether, on principle and authority, such actions can be sustained, when the award is adjudged valid and is pleaded in bar, is the remaining question for consideration.

It is admitted by the pleadings, that the demand in suit has not in fact been paid. It is, also, admitted, that it was not examined and allowed by the arbitrators ; nor is there any pretence, that it has been discharged in any way except by the operation of a technical principle, rendering it, as contended by the defendant, rem adjudicatam. That technical principle is fully illustrated in the cases of Tilton vs. Gordon—Robison vs. Crowninshield, (1 New Hamp. Rep. 35, 76) and the authorities there cited. See also, 1 John. Cases 436.—14 John. 63, 377, 466.—15 Mass. Rep. 207.—1 Wm. Bl. 221.—1 Scho. & Lef. 201.—1 Wheaton Rep. 452.—Justin. Inst. 594.

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