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Michigan Law Review

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Crimes-Larceny-By Wife From Husband Feb 1932

Crimes-Larceny-By Wife From Husband

Michigan Law Review

A wife was convicted of larceny of her husband's property. Upon appeal from an order denying a new trial, held that the order be reversed: The Married Woman's Act, reading, "every married woman shall receive the same protection of all her rights as a woman which her husband does as a man," does not so change the common law unity of spouses that a wife stealing from her husband is included under the comprehensive terms of the larceny statute. State v. Arnold, 182 Minn. 313, 235 N.W. 373 (1931).


Gifts Causa Mortis - Contemplation Of Suicide Feb 1932

Gifts Causa Mortis - Contemplation Of Suicide

Michigan Law Review

The testator, suffering from melancholia and contemplating suicide, purchased a certificate of stock in the name of his brother and caused it to be deposited in a bank by the latter. Over two months thereafter, the testator stated, in effect, that in the event of his death the certificate should become the brother's property. Held, in affirming the allowance of the final account of the executor, that the transfer of the certificate was a valid gift causa mortis. In re Van Wormer's Estate, 255 Mich. 399, 238 N.W. 210 (1931).


Courts-Discretion To Refuse Jurisdiction-Forum Non Conveniens Feb 1932

Courts-Discretion To Refuse Jurisdiction-Forum Non Conveniens

Michigan Law Review

In these days of frequent travel and of corporations doing business in many states, a plaintiff with a transitory cause of action often can get personal service on defendant in more than one jurisdiction. This privilege may be abused, and to meet such abuse a plea of forum non conveniens is proper, the substance of which, as its name implies, is that the forum is not appropriate for the trial of the suit. Where either of the parties is a resident, or where the cause of action arose within the jurisdiction, the forum will usually be as appropriate as any, …


Bills And Notes - Is One Assuming Liabilities To The Creditors Of His Transferor A Holder In Due Course Feb 1932

Bills And Notes - Is One Assuming Liabilities To The Creditors Of His Transferor A Holder In Due Course

Michigan Law Review

The plaintiff entered into an agreement whereby it was to receive all the assets of an insolvent bank as consideration for the assumption of certain specified liabilities. Among the assets was a note upon which the plaintiff is now suing a prior indorser. Although it was the intention of the defendant to indorse as agent in accordance with the request of the insolvent bank, on the face of his endorsement he indorsed individually. Held, that since the plaintiff was not a holder in due course, the note was subject to the same defenses in the hands of the plaintiff …


Front Matter, Michigan Law Review Jan 1932

Front Matter, Michigan Law Review

Michigan Law Review

Front Matter for Volume 30, Issue 3 of Michigan Law Review


Foreign Diplomats And The Prohibition Laws, Lawrence Preuss Jan 1932

Foreign Diplomats And The Prohibition Laws, Lawrence Preuss

Michigan Law Review

Notwithstanding the general and inclusive nature of the Eighteenth Amendment and of the enforcement legislation enacted under its terms, the executive departments of the national government have acted on the assumption that foreign diplomats are exempted from the operation of the prohibition laws, and have issued regulations by which the importation of liquor by members of this class is permitted. According to statements of the responsible officers concerned, this privilege is based upon "international comity and usage," and upon "the established principles of international Jaw and the statutes of the United States, including the provisions of sections 4063-4065 of the …


Legislation - Old Age Pensions Jan 1932

Legislation - Old Age Pensions

Michigan Law Review

Out of our changing social theories has grown modern social legislation. The tendency is nowhere better illustrated than in the development of legislation for the care of aged persons. During the last decade great strides have been made in enacting such legislation, and the present year has seen increased activity, leading to the passage of old age pension laws in five states and to numerous other legislative accomplishments.


Attorney And Client - Disbarment - False Testimony Jan 1932

Attorney And Client - Disbarment - False Testimony

Michigan Law Review

A, an attorney, as a witness for his client in a suit against the latter, testified falsely under oath with knowledge of the fact. In proceedings for disbarment, during which A admitted the falsity of his testimony, held, his conduct warranted suspension from the bar for one year. Green v. State Bar ( Cal. 1931 ) 2 Pac. ( 2d) 340.


Transfer Of Future Interests, W. Lewis Roberts Jan 1932

Transfer Of Future Interests, W. Lewis Roberts

Michigan Law Review

In considering to what extent future interests are transferable in this country it is proposed to limit the investigation to those future interests known as contingent remainders, executory devises, and defeasible vested remainders. It has not been deemed necessary to consider vested remainders as they have long been treated by the law in much the same way as present estates have been as far as alienation is concerned.


Legislation - Unemployment Insurance Bills Jan 1932

Legislation - Unemployment Insurance Bills

Michigan Law Review

The ever-present problem of unemployment is today particularly acute. The ultimate aim, of course, must be to put an end to unemployment. But achievement of this aim is not in sight, and in the meantime we are set the task of mitigating, so far as possible, the sufferings incident to unemployment. The laissez-faire attitude toward social problems is passing, and an increasing opinion accepts this task of mitigation as resting on society. In 1908 Sir William Beveridge was able to write: "There has been thus a steady, if gradual, growth of the sense of public responsibility for the case of …


Constitutional Law - Self-Incrimination - Effect Of State Immunity Statute In Federal Court Jan 1932

Constitutional Law - Self-Incrimination - Effect Of State Immunity Statute In Federal Court

Michigan Law Review

The defendant was indicted for violation of the National Prohibition Act. He pleaded immunity from prosecution in the federal court because of his forced testimony in the trial of another in the state court. Held, the state immunity statute was ineffective to protect the defendant in a federal court. United States v. Smith, 51 F.(2d) 803 (1931).


Contracts - Illegality- General Restraint Of Trade Jan 1932

Contracts - Illegality- General Restraint Of Trade

Michigan Law Review

Defendants sold their stock in a manufacturing corporation with a covenant in the contract to the effect that they would not engage in the sale or manufacture of bunghole appliances in the United States, east of the Mississippi, for a period of sixteen years. Held, a contract which does not permit one to engage in his trade anywhere within the state is one in general restraint of trade and is ipso facto illegal and void. Parish et al. v. Schwartz et al. (Ill. 1931) 176 N.E. 757.


Alteration Or Replacement Of Buildings By The Long-Term Lessee, Marvin L. Niehuss Jan 1932

Alteration Or Replacement Of Buildings By The Long-Term Lessee, Marvin L. Niehuss

Michigan Law Review

The first Reform Bill of 1832 was at once a symptom and a further cause of momentous changes in English institutions, political and legal, to say nothing of social and ecclesiastical. Many of these were brought about as the result of patient and competent investigations of royal commissions which, though not unknown before the third decade of the nineteenth century, were active to an extent hitherto unheard of during that notable epoch of reform. While a few men of law were among the forward spirits, the bulk of the advance guard were laymen. As a rule judges, barristers and attorneys …


Equity - Estoppel By Injunction In Subsequent Suit At Law For Damages Jan 1932

Equity - Estoppel By Injunction In Subsequent Suit At Law For Damages

Michigan Law Review

A leased to B a shop to be used as a public market. The lease contained a restrictive covenant by the lessor to lease no other shops for a like purpose. The lessor, however, leased to C, who was engaged in the same business as B, one of the shops so restricted. C took with knowledge of the restrictive covenant in B's lease. B, the plaintiff in this action, secured a final injunction in a New York court enjoining the use by C. Under the New York statute B could have obtained damages under the equity decree, but failed to …


Landlord And Tenant -Adverse Possession And Prescription-Based On Holding And User By Tenant Jan 1932

Landlord And Tenant -Adverse Possession And Prescription-Based On Holding And User By Tenant

Michigan Law Review

A tenant who enters under a valid lease can, if he denies his landlord's title, and holds openly, notoriously, and adversely to him for the statutory period, acquire title by adverse possession. But suppose the tenant enters under a void lease and holds for the statutory period, claiming merely under the lease. It seems that there are three possible views as to the legal effect of his holding.


Fixtures - Rights Of Conditional Vendors -Test Of Material Injury To Freehold Jan 1932

Fixtures - Rights Of Conditional Vendors -Test Of Material Injury To Freehold

Michigan Law Review

Plaintiff sued to foreclose a mortgage on a hotel. Defendants were vendors of various pieces of hotel equipment, who apparently had filed title-retaining contracts subsequent to the recording of the realty mortgage. The court found that some of the equipment was not attached to the realty at all, and that the rest could be removed without material in jury to the "freehold." Held, that the title of the conditional vendors prevailed, under N. J. Comp. Stat. supp., secs. 182-93. Bank of America National Ass'n. v. LaReine Hotel Corp. (N. J. 1931) 156 Atl. 28.


Practice And Procedure - Demurrer To Evidence - Directing Verdict In Favor Of Party Having Burden Of Proof Jan 1932

Practice And Procedure - Demurrer To Evidence - Directing Verdict In Favor Of Party Having Burden Of Proof

Michigan Law Review

P purchased potatoes in Michigan. He instructed the defendant railroad to deliver the potatoes to the warehouse of B when they should arrive in Richmond. Instead, some were sent to another warehouse. Before P discovered the mistake, the potatoes spoiled. P made claim of loss six months and twenty days after the shipment left Michigan. The bill of lading provided that claims for loss or damage must be made in writing within six months after a reasonable time for delivery has elapsed. The testimony of Neiss, freight clerk, who was called by the defendant, was to the effect that eight …


Corporations - Service Of Process On A Subsidiary Corporation Doing Business In The State In An Action Against A Foreign Corporation Jan 1932

Corporations - Service Of Process On A Subsidiary Corporation Doing Business In The State In An Action Against A Foreign Corporation

Michigan Law Review

The Freeport Texas Company, a Delaware corporation, owned all of the stock of the Freeport Sulphur Company, a Texas corporation, except a few qualifying shares. The directorates of the two corporations were interlocking; officers of the parent corporation occupied identical positions in the subsidiary; and common offices were occupied in New York. It also appeared that the board of the Texas corporation only passed on local operating matters and ratified ordinary contracts. The sales end of the organization was operated from New York and the board had no control over it. The fixing and payment of salaries, the amount of …


Torts - Fraud - Spoliation Of Will Jan 1932

Torts - Fraud - Spoliation Of Will

Michigan Law Review

In a suit in tort for damages, plaintiff alleged that defendant, heir-at-law of the decedent, suppressed a genuine will under which the plaintiff was devisee, and forged and fraudulently probated a will which did not contain the devise to the plaintiff who remained in ignorance of both the fraud and the existence of the genuine will for more than twenty years. The defendant demurred. Held, that the plaintiff has a cause of action in tort. Morton v. Pettit, 38 Ohio App. 348, 176 N.E. 494 (1930), aff'd., (Ohio 1931) 177 N.E. 591.


Evidence - Burden Of Proof - Compliance With Stipulation In Bill Of Lading As To Time For Claim Of Loss Jan 1932

Evidence - Burden Of Proof - Compliance With Stipulation In Bill Of Lading As To Time For Claim Of Loss

Michigan Law Review

P purchased potatoes in Michigan. He instructed the defendant railroad to deliver the potatoes to the warehouse of B when they should arrive in Richmond. Instead, some were sent to another warehouse. Before P discovered the mistake, the potatoes had spoiled. P made claim of loss six months and twenty days after the shipment left Michigan. The bill of lading provided: "Sec. 2 (b). Claims for loss or damage . . . must be made in writing . . . within six months after a reasonable time for delivery has elapsed." The testimony of Neiss, freight clerk, who was called …


Damages - Death Of Minor Child Caused By Negligent Act Jan 1932

Damages - Death Of Minor Child Caused By Negligent Act

Michigan Law Review

The defendant's negligence, resulting in the death of a child four years and nine months old, caused the jury to assess damages at $4,500 in an action brought for the benefit of the parents pursuant to the terms of the Death Act, (2 N. J. Comp. Stat. 1907, 1908 (1910)) which provides that "in every such action the jury may give such damages as they shall deem fair and just with reference to the pecuniary injury resulting from such death . . . . " On appeal, the supreme court held the damages excessive, and reduced the amount of recovery …


Equity - Power To Rescind Conveyance For Fraud - Survival Jan 1932

Equity - Power To Rescind Conveyance For Fraud - Survival

Michigan Law Review

When a party has been induced by fraud to make a conveyance of real estate, he has a choice of remedies against the defrauding grantee. He may seek restitution of the land or its proceeds in equity or at law on a theory of rescission, or he may affirm the transaction and bring an action for the recovery of damages for the deceit. The actions being logically inconsistent, the granter is not allowed to proceed in both, and must elect whether he will have his property returned to him in specie on his restitution of the price received from the …


Trusts -Tracing Of Assets - Preference Jan 1932

Trusts -Tracing Of Assets - Preference

Michigan Law Review

In State ex rel Sorenson v. Farmers' State Bank of Polk (Lindquist, Intervenor) the beneficiary of a trust fund converted by the bank, subsequently becoming insolvent, was allowed to resort to equity and recover the trust fund as a preferred claim against the general assets of the bank. The beneficiary deposited a promissory note in the sum of $4,500 in the bank for a special purpose and the bank, without authority, indistinguishably mingled the proceeds of this note with the general mass of bank assets. The amount of actual cash on hand when the insolvent bank was taken over by …


Banks And Banking - Joint Deposits Jan 1932

Banks And Banking - Joint Deposits

Michigan Law Review

Funds originally belonging to the wife were deposited in a joint account for the husband and wife, it being stipulated that the money was to be withdrawn upon the order of both, and that, upon the death of either, the survivor should have an absolute right to the balance. The husband died and his administrator brought an action to recover one-half of the funds. Held, the money belonged to the wife on any theory of the case which might be developed. Hollingsworth v. Hollingsworth (Iowa 1931) 235 N.W. 726.


Bills And Notes - Estoppel As Against Bona Fide Purchaser Of Non-Negotiable Chose Jan 1932

Bills And Notes - Estoppel As Against Bona Fide Purchaser Of Non-Negotiable Chose

Michigan Law Review

Plaintiffs bought some interim certificates (at that time non-negotiable in New York), and delivery was made to them. Because of inability to make payment that day, they asked the vendor to send a runner for the certificates, and when a person appeared asking for the amount due the vendor, plaintiffs' cashier gave him the certificates. Shortly thereafter the proper runner arrived, and plaintiff's at once gave notice of the theft in newspapers and otherwise. Some of the stolen certificates were pledged with defendant who acted in good faith in taking them. The defense to this suit for recovery of the …


Bills And Notes - Negotiation - Implied Warranties Jan 1932

Bills And Notes - Negotiation - Implied Warranties

Michigan Law Review

In a suit by the payee against the maker of a note, the defense was a failure of the consideration, i.e., several assigned drafts had been paid at the time of the assignment. It did not appear whether these unendorsed drafts were order or bearer instruments. Held, under the Negotiable Instruments Law this is not a failure of consideration because the assignor warrants only facts within his knowledge, and evidence of knowledge of these facts by the assignee is admissible to rebut the implied warranty. Queensboro Nat. Bank. v. Kelly, 48 F.(2d)574 (1931).


Bills And Notes-Payee Of Note Is Holder In Due Course Unless Contrary Appears Jan 1932

Bills And Notes-Payee Of Note Is Holder In Due Course Unless Contrary Appears

Michigan Law Review

Defendant, who had jointly signed (ostensibly as maker) a note containing the words, "I promise to pay," was held not entitled to show by parol evidence that he was an accommodation indorser, under 2 MICH. COMP. LAWS 1929, secs. 9249, 9266 (N. I. L., sec. 17), and 9309 (N. I. L., sec. 60), the court saying, by way of dictum, that, in the absence of a contrary showing, the payee named in a promissory note payable to order is a holder in due course. Price v. Klett (Mich. 1931) 238 N.W. 253.


Bills And Notes - Restrictive Indorsement Jan 1932

Bills And Notes - Restrictive Indorsement

Michigan Law Review

Plaintiff sued defendant to enforce the collection of two promissory notes which defendant indorsed in blank to X Bank. X Bank indorsed the notes to "Y Bank, as trustee." Y indorsed the notes to plaintiff. All the indorsements were before maturity and for value. Held, on the pleadings, that the order overruling the demurrer to the declaration be sustained. In a concurring opinion, Brown, J., stated that an indorsement to a corporation or person with the words, "as trustee," after the name is not a restrictive indorsement within the meaning of the Uniform Negotiable Instruments Law, sec. 6796, 7, …


Conflict Of Laws - Remarriage After Divorce Jan 1932

Conflict Of Laws - Remarriage After Divorce

Michigan Law Review

H obtained a divorce in Alabama under a statute prohibiting remarriage without. permission of the court. He remarried in Tennessee, where the statute prohibited remarriage during the life of the other spouse. Held, the Tennessee law applied to divorces obtained in that state only. In the absence of express words. to that effect, the Alabama statute had no extra-territorial effect; and the marriage, valid where performed, was valid everywhere. Smith v. Goldsmith, (Ala. 1931) 134 So. 651. H secured a divorce in Vermont under a statute declaring void any remarriage within three years, either within or without the …


Contracts - Parties - Suit On A Sealed Instrument Jan 1932

Contracts - Parties - Suit On A Sealed Instrument

Michigan Law Review

Defendant was the obligor on a bond under seal given for the faithful performance of a shipbuilding contract in which the obligee was named as "the United States Shipping Board Emergency Fleet Corporation; a corporation organized and existing under the laws of the District of Columbia, representing the United States of America." The contract, to insure the performance of which the bond was executed, was signed by the "Fleet Corporation" and sealed with its own seal. In action at law on the bond brought by the United States, held, since the plaintiff was not a party named in the …