Wingate v. Parsons

4 Del. Ch. 117
CourtCourt of Chancery of Delaware
DecidedMarch 15, 1871
StatusPublished
Cited by1 cases

This text of 4 Del. Ch. 117 (Wingate v. Parsons) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wingate v. Parsons, 4 Del. Ch. 117 (Del. Ct. App. 1871).

Opinion

The Chancellor :—

The complainants, husband and wife, join in a suit for a legacy bequeathed to the wife during the coverture. • The defendants, executors of the testator who made the bequest, seek to retain the legacy against a debt due .from the husband to. the testator in his lifetime. Can this be done either by way of set-off under the statute ? or, if not under the statute, then can it be done under any equitable power of this Court independently of the statute ? These were the questions raised in the argument.

And first, is this a case of set-off within the statute ? I am clearly of the opinion that it is not. The statute (Rev. Code 380, Sec. 21) is expressly limited to “mutual “debts” between the parties to an action due “in the “ same right. The plain meaning of this phrase “due in “the same right,” is that a debt due from A alone shall discharge only a debt due to A alone ; or that a debt of one character i. e., whether several or joint, individual or representative, shall discharge a debt of the like character and no other. The object or policy of the provision is to save from the operation of the statute all cases in which there attaches to one of the claims, proposed to be set off, some right or interest which would be unjustly discharged or prejudiced by the set-off. Thus a [123]*123joint debt cannot be set off against a several one, because the rights of the joint creditor on the one side would thereby be unjustly extinguished by setting off a claim partly belonging to him against a debt for which he is not liable. So a debt, due to an executor or administrator, he cannot set off against his individual debt, because this would be to pay his debt with assets belonging to the creditors and legatees or distributees whom he represents. So,upon precisely the same principle,it is against the terms and policy of the statute, to discharge the debt of the husband with the wife’s legacy. For the wife, notwithstanding her marriage, does retain in a legacy, bequeathed to her and not yet reduced to her hnsband’s possession, an interest, termed her right of survivorship. Now, as to the precise, nature of this right of survivorship, different views have been expressed, some judges considering that by marriage the title vests in the husband, but subject to a right or privilege of survivorship to. the wife, if not reduced to possession and she survive him, Johnson vs. Fleetwood, 1 Harring. 442, and others considering that the title remains in the wife, subject, merely, to the husband’s control and power to reduce it to his own possession. Gibson C. J. in Timbers vs. Katz, 6 W. & S. 290. The difference is not material to this case. It is quite sufficient that the wife’s right of survivorship, whatever may be its nature, is treated by the law, as unquestionably it is, as an interest of substance and importance and entitled to protection as scrupulously as is the right of a joint creditor or of the creditors and legatees or distributees of an estate, in the case before put, in which set-off is excluded.

The favor with which the law regards the wife’s interest in her choses in action is seen in the strictness of the rule as to what shall be sufficient to extinguish her right.

First, we may observe, as a general principle, that the husband only can determine his wife’s right of survivor-ship- at his free election. His creditors cannot-interfere [124]*124with'- it .except under some special statutory provisión. Hence,-generally,"it has been held'thkt the wife’s chose in action cannot be attached by the husband’s creditors. Dennison vs. Nigh, 2 Watts 90; Marston vs. Carter, 12 N. H. 159. In this State the wife’s chose in action may be attached by'the'husband’s creditors'. Johnson vs. Fleetwood, 1 Harring. 442; That decision however rests upon the ground that , our attachment law, in defining the subjects which may be attached, uses the word “rights” which, the Court held, includes- the right of the husband to reduce the chose in action to his'possession, to which, by force of. the statute, the creditor might succeed, but the same decision expressly holds the wife’s interest to be unaffected by the attachment,, until an actual reduction to possession is effected by the attaching creditor, thus saving the rights of the wife as far as the phraseology of the statute would admit. The Court sáy “if he” (the attaching creditor) “can possess him- " self of the debt before the husband dies, it is his ; if he “ does not.do this, then the wife if she survives would be en- “ titled to it.” Of the same effect is an attachment in Massachusetts, 1 Mete. 476. With respect to what acts of the. husband are sufficient to extinguish the .wife’s right, the law is extremely rigorous. It is now a settled. principle that nothing short of actual and positive: reduction. into possession by the husband, or a release or an assignment for a valuable considesation, and that of & chose, in action presently reducible to possession, is sufficient to bar the wife’s right by survivorship to her chases in action. A voluntary assignment by the husband without consideration does not bind her. 2 Kent (137). It has been.a subject of long controversy whether an assignment, even for a consideration, should pass to his assignee more than .the husband’s power to reduce the chose in action to possession, subject to the wife’s right of survivorship, should the husband die meanwhile. It is at last settled, that an assignment for value does of itself bar the wife’s right to a chose in action,-presently; reducible to ' posses- - [125]*125sion, though not as to reversionary interests. 2 Kent, (137) (138) note (a). ■

Let us now note how far the regard of the courts, for the wife’s interest, has gone in holding the husband to most positive and unequivocal acts of conversion, in order to alter the property and bar the wife. It has been held, that the appropriation, out of the estate of a testator, of a specific fund, as a mortgage, for payment of a legacy bequeathed to a wife, by an arrangement between the executor and the husband, and the making of some payments of interest to the husband, for which he receipted, was not a sufficient reduction to his possession to divest the wife’s right of survivorship. Blount vs. Bestland, 5 Ves. 515. The husband, proving the wife’s debt under a commission of bankruptcy and paying the contribution money, was held not to alter the property, so as, on his death, to defeat her right to the dividends. Anon. 2 Vern. 707. Payment of the wife’s legacy into court, under a decree establishing the right of husband and wife in her right, but before any order for payment to the husband, is not sufficient. Bond vs. Simmons, 3 Atk. 20; Macaulay vs. Philips 4 Ves. 17; Clancy on M. W. 119. Payment of interest and part payment of principal, to the husband, of his wife’s chose in action, is not a reduction to his possession of the balance. Nash, vs. Nash, 2 Madd. 133 (1 Dan. Ch. Pr. 149). Even where money due to the wife comes into the hands of the husband, that is not sufficient, so long as his possession is referable to any other right than the marital right, as in Baker vs. Hall, 12 Ves.

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Related

Walker v. Caldwell
8 Del. Ch. 91 (Court of Chancery of Delaware, 1896)

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Bluebook (online)
4 Del. Ch. 117, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wingate-v-parsons-delch-1871.