Page images
PDF
EPUB

overvaluation of property transferred to the corporation in payment of the shares, the transaction, unless void for the same reason, is binding so long as it is not impeached by the corporation or its assignee, and it can be impeached only for fraud upon the corporations." Coffin v. Ransdell, 110 Ind. 417, 11 N. E. 20. In each of the two cases just referred to, there was a charge that the property received by the corporation in payment of stock was taken at an overvaluation.

In a later case decided by the supreme court of Indiana, the opinion is concluded in these words: "In disposing of this case, we think it proper to say that it is apparent that the issues were not broad enough to permit the introduction of the evidence by which the appellants sought to establish their case. The case made in the pleadings depended entirely upon the allegations of noncollections of the capital stock of the company. The order made by the board of directors introduced by the plaintiffs, and the contract between the water company and Comeggs & Lewis, given in evidence by defendants, show that the full amount of the capital stock had been paid to the satisfaction of the contracting parties. In the well-considered case of Coffin v. Ransdell, 110 Ind. 417, 11 N. E. 20, it was held by this court that such payment could only be impeached for fraud. No suggestion of fraud is made in the pleadings, and, without making charge of fraud in the complaints, the plaintiffs could introduce no evidence to show or tending to show fraud, as a basis of recovery." Clow v. Brown (Ind. Sup.) 31 N. E. 362. In a case somewhat like the one before us, the supreme court of Maryland has said: "So long as the transaction stands unimpeached for fraud, courts will treat as a payment that which the parties themselves have agreed shall be a payment; and this, too, in cases where the rights of creditors are involved." Brant v. Ehlen, 59 Md. 1.

Mr. Cook says: "It is now well settled that, in order to invalidate an issue of stock which is issued for property taken at an overvaluation, it must be shown, not only that there was an overvaluation, but also that such overvaluation was intentional, and consequently fraudulent." Cook, Stocks & S. §§ 35, 47. Mr. Thompson, after considering the question of paying for shares in property through several sections of his work on Liability of Stockholders, concludes as follows: "The whole discussion resolves itself into the following conclusions: A corporation may take in payment of its shares any property which it may lawfully purchase. Such a transaction is not ultra vires or void, but is valid and binding upon the original sharetakers, and upon the corporations, unless it is rescinded or set aside for fraud. While such a contract stands unimpeached, the courts, even where the rights of creditors are involved, will treat that as payment which the parties have agreed shall be pay

ment." Thomp. Liab. Stockh. § 134. Mr. Taylor, after announcing as well recognized the rule that property may be taken in payment for stock, continues: "Such transactions may be opened to show fraud, and, if the property received is grossly unequal in value to the par value of the shares, the shareholder who received the shares originally, or his subsequent transferees with notice of the circumstances, may be compelled to make up the difference in values in a suit brought by or on behalf of persons injured thereby." Tayl. Priv. Corp. § 545. Mr. Spelling says that such transactions "have been upheld against creditors only where the contract for the rendition of services or the purchase of property payable in stock has been made in good faith, and the property taken in payment has been put in at a fair bona fide valuation. Such payment discharges a party from his liability to creditors upon his subscription, though it be excessive, provided that, in fixing and accepting it, the agents of the company have acted in good faith." 2 Spel. Priv. Corp. § 792.

Gogebic Invest. Co. v. Iron Chief Min. Co. is a case in which a creditor of an insolvent corporation sued certain of its stockholders to recover unpaid stock, upon the allegations that they had transferred to the corporation certain mining property at 10 times its real value, and obtained therefor, full-paid stock. Hearing the case on demurrer, the court said: "In an action against the stockholders of a corporation to compel them to contribute to the payment of the debts of the insolvent corporation, it is only necessary, in order to make out a prima facie case, to establish the fact that the stockholder has not in good faith paid the par value of his stock to the corporation." In the same case it is said: "The allegations of the complaint, which are admitted to be true by the demurrer, show conclusively that the stockholders (defendants) have not, as between themselves and the creditors, paid in full for their stock, and are therefore liable to make further payment, for the benefit of the plaintiff, as a creditor of the corporation. This is all that is necessary, under our statute or at common law, to make a case against the stockholders of unpaid stock in favor of a creditor of the insolvent corporation." 78 Wis. 427, 47 N. W. 726. Similar relief was sought in the case of Elyton Land Co. v. Birmingham Warehouse & Elevator Co. "The statements of fact in the bill support the conclusion therein averred, that the transaction by which payment for the stock was attempted to be made was merely colorable; in other words, that it was not really a payment, but had only the outward appearance, without the substance, of a payment. Such being the case, the individual defendants are still liable on their stock subscriptions, to the extent that the attempted payment falls short of a bona fide compliance with the terms of the contract; and the allegations as to excessive

overvaluation of property in question were sufficient, under the rules above stated." 92 Ala. 407, 9 South. 129. The late case of Lloyd v. Preston is one in which creditors of an insolvent corporation sought to compel a stockholder to pay his subscription. In the original bill, complainants alleged that no part of stock subscription had been paid. Defense was made, on the grounds, as claimed in the answer, that full payment had been made by the transfer of property. Thereupon an amended bill was filed, alleging collusion between the directors of the corporation and the defendant Harper, and that the property transferred by Harper to the company was not worth one "fiftieth part" of the sum at which he sold it, and that he knew that fact at the time. The hurtful part of the amended bill was denied by Harper. The circuit court, hearing the case upon these pleadings and proof, found "that the entire organization was grossly fraudulent, from first to last, without a single honest incident or redeeming feature." Mr. Justice Shiras, speaking for the supreme court, on appeal, said: "It having been found, on convincing evidence, that the overvaluation of the property transferred to the railway company by Harper, in pretended payment of the subscriptions to

capital stock, was so gross and obvious as, in connection with the other facts in the case, to clearly establish a case of fraud, and to entitle bona fide creditors to enforce actual payment by the subscribers, it only remains to consider the effect of the defenses set up." 146 U. S. 642, 13 Sup. Ct. 131.

The foregoing quotations from text writers and adjudicated cases abundantly sustain the proposition that the transaction whereby Lambie obtained full-paid stock as the price of property conveyed must stand until impeached by appropriate allegation and proof; and that, until that is done, no liability can be fixed upon a holder of that stock for further payment. No such liability can arise by presumption from the mere fact that property, instead of money, was used in paying for the stock. This is conclusive of the whole case, for all of the defendants are holders of parts of the Lambie stock, all of which, upon this record, must be treated as full paid and nonassessable, whether purchased by the present holders from the corporation, one of his transferees, or from him directly. In the hands of Lambie it would be so regarded. In the hands of others, after him, whether donor or purchaser, it is at least upon as high a plane. Let the decree be affirmed.

END OF CASES IN VOL. 28.

INDEX.

[blocks in formation]

trators."

[ocr errors]

On injunction bond, see "Injunction."
On insurance policy, see "Insurance.'
On note, see "Negotiable Instruments."
Particular forms of action, see "Attachment";
"Death by Wrongful Act"; "Divorce";
"Ejectment"; "Libel and Slander"; "Repley
in"; Trespass to Try Title"; "Trover and
Conversion."

To set aside fraudulent conveyances, see
"Fraudulent Conveyances."

Where a person contracts to pay debts of an-
other, the creditors of the latter may sue on the
contract.-Winner v. Lippincott Inv. Co. (Mo.)

998.

An agent who receives a sum of money from
his principal, to be paid to a third person, is
individually liable to such person for the sum
received.-Mathonican v. Scott (Tex. Sup.) 1063.
v.28s.w.-70

Where one person covenants to pay the debts
of another, the creditors of the latter may sue
on the covenant.-State v. St. Louis & S. F.
Ry. Co. (Mo.) 1074.

Where one person merely agrees to "save
harmless" another against the claims of third
persons, the latter cannot sue on the agreement,
as it is not made for their benefit.-State v. St.
Louis & S. F. Ry. Co. (Mo.) 1074.

A plaintiff declaring in assumpsit for goods
sold may also declare for an unlawful conver-
sion of the same goods.-Compton v. Ashley
(Tex. Civ. App.) 223.

[blocks in formation]

ADVERSE POSSESSION.

The possession of heirs is not adverse to a
purchaser at an administrator's sale for the pay-
ment of debts.-Rogers v. Johnson (Mo.) 635.

One who purchases the interest of a dowress,
before dower has been assigned, cannot, during
her lifetime, hold the land adversely to the
heir.-Melton v. Fitch (Mo.) 612.

A widow whose dower has never been as-
signed cannot, by remaining in possession, ac-
quire title as against her son, a minor heir.-
Fisher v. Siekum (Mo.) 435.

exclusive right under a deed, is adverse to his
The possession of one tenant, asserting an
cotenant having notice of the deed.-Puckett v.
McDaniel (Tex. Civ. App.) 360.

The registration of a deed under which a ten-
ant in common claims is notice to his cotenant.
-Puckett v. McDaniel (Tex. Civ. App) 360.

Where an owner builds over the line by mis-
take as to the boundary, open and exclusive pos-
session, with intent to hold adversely, consti-
tutes adverse possession.-Wilson v. Hunter
(Ark.) 419.

Propriety of instruction as to what must be
shown by one claiming land by adverse posses-
sion.-Parker v. Covey (Tex. Civ. App.) 64.

Possession by husband and wife construed to
be, in legal effect, the sole possession of the
wife, she having paper title under a deed from
her husband in fraud of creditors.-Potter v.
Adams (Mo.) 490.

(1105)

Evidence examined and held sufficient to show
color of title and adverse possession.-Dollar-
hide v. Mabary (Mo.) 332.

Question whether the possession of one un-
der color of a void judgment allotting the land
to her in divorce proceedings is changed into
a claim under her dower right by the death of
her husband.-Jones v. Thomas (Mo.) 76.

Right of court to presume the existence of a
certain deed, referred to in a later one, and
under which there was an assertion of owner-
ship for more than 30 years. - Harrison v.
Friar (Tex. Civ. App.) 250.

-

Question whether one of two adjoining land-
owners had adverse possession of land of the
other from which he occasionally cut wood.
Golterman v. Schiermeier (Mo.) 616.

Sufficiency of evidence to show adverse pos-
session.-Smith v. Estill (Tex. Sup.) 801.

Time of accrual of right of action for land
which was attempted to be conveyed by a mar-
ried woman by a conveyance which merely re-
leased her dower, but of which the grantee
took possession, claiming an absolute estate.
Brown v. Swango (Ky.) 156.

[blocks in formation]

the right of one defendant to part of the land
involved, is not a final judgment from which
a writ of error lies to the supreme court. -
Schmidt v. Huff (Tex. Sup.) 1055.

No appeal lies from an order of the United
States court remanding a case to a state court.
May v. State Nat. Bank (Ark.) 431.

Where affidavit on appeal is not filed within
20 days, and appellant is a resident of the
county, the supreme court acquires no jurisdic
tion.-Dixon v. Southern Bldg. & Loan Ass'n
(Tex. Civ. App.) 58.

Where the affidavit does not identify the judg-
ment appealed from, it confers no jurisdiction.
Dixon v. Southern Bldg. & Loan Ass'n (Tex.
Civ. App.) 58.

Notice.

Where a city is not required to give bond on
appeal, its appeal is perfected when notice is
given.-City of Hallettsville v. Long (Tex. Civ.
App.) 573.

The court of civil appeals can determine wheth-
er notice of appeal was served. the fact being
omitted from the transcript.-Western Union
Tel. Co. v. O'Keefe (Tex. Sup.) 945.

Notice of appeal cannot be waived.-Western
Union Tel. Co. v. O'Keefe (Tex. Sup.) 945.
Bond.

Where the bond identifies the judgment, it
is sufficient, though one recital may be indefi-
nite.-Crow v. Curry (Tex. Civ. App.) 715.

An appeal bond, filed in a justice court, exe
cuted by one of several defendants against
whom there is a joint judgment, is sufficient.-
Ayers v. Smith (Tex. Čiv. App.) 835.

A bond to the St. Louis court of appeals in-
stead of the appellate court is not sufficient-
American Brewing Co. v. Talbot (Mo.) 585.

Where the bond is insufficient on its face,
the supreme court may set aside the approval,
and require a sufficient bond.-American Brew-
ing Co. v. Talbot (Mo.) 585.

The omission of the number of the case and
the names of all the parties from the bond on.
appeal from a justice is not fatal.-Farror v.
Dowd (Tex. Civ. App.) 919.

Error in dismissing an appeal from a justice
because of insufficiency in the bond will be re-
viewed in the absence of an assignment of er-
ror.-Farror v. Dowd (Tex. Civ. App.) 919.

The appeal of a nonresident in the trial coun-
ty, who fails to file his bond within 30 days
from notice of appeal, will be dismissed-South-
ern Pac. Co. v. Phillipson (Tex. Civ. App.) 55.

An affidavit stating that appellant is unable
to give an appeal bond must be filed within the
statutory time in order to confer jurisdiction.-
Vestal v. Reese (Tex. Civ. App.) 54.

A bond which recites that "we acknowledge
ourselves to owe and be indebted" to appellee
is sufficient.-Lewis v. Sproles (Tex. Civ. App.)

Where, pending an action on a note for $80,
secured by a mortgage on personal property
worth $150, the property is destroyed, an ap
peal to the court of civil appeals will not lie.-94.
Tufts v. Hodges (Tex. Civ. App.) 110.

A guardian ad litem and the next friend of
minors may appeal whenever it is necessary to
protect the interests of the wards.-Loftis v.
Loftis (Tenn.) 1091; Brooks v. Same, Id.; Lof-
tis v. Brooks, Id.

An administrator can appeal from an order as
to apportionment of the estate among creditors.
Jamison v. Adler-Goldman Commission Co.
(Ark.) 35.

Where a petition for rehearing is pending in
the superior court, the right to appeal does not
accrue until it has been overruled.-Northwest-
ern Mut. Life Ins. Co. v. Barbour (Ky.) 156.

A judgment of the court of civil appeals, in
a suit of trespass to try title, determining ouly

Where judgment in garnishment is against
defendant and the garnishee, on appeal by de-
fendant the bond should be payable to plaintiff
and the garnishee.-Bauer v. Adkins (Tex. Civ.
App.) 1009.

Appeal from inferior courts.

On appeal from a justice's judgment, an an-
convention an amount in excess of a justice's
swer cannot be amended so as to set up in re-
jurisdiction. - Ostrom v. Tarver (Tex. Civ.
App.) 701.

-

On appeal from a justice's judgment, an an-
swer cannot be amended so as to allege fail-
ure of consideration, no such defense having
been made in the justice's court.-Ostrom v..
Tarver (Tex. Civ. App.) 701.

« PreviousContinue »