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Doe v. Hyde, Assignee

• 1884 • 114 U.S. 247 • Waite Court
Doe v. Hyde, Assignee was a United States Supreme Court case that addressed the issue of whether a debtor could be held liable for a debt that was assigned to another party. The case involved a dispute between John Doe and William Hyde, who had been assigned a debt that Doe had previously owed to another party. The Supreme Court held that a debtor cannot be held liable for a debt that has been assigned to another party. The Court reasoned that the assignment of a debt is a transfer of the right...Open Case
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Chief Waite Court
Term: 1884
Docket: 218
114 U.S. 247
5 S. Ct. 841
29 L. Ed. 142
1885 U.S. LEXIS 1755

Doe v. Hyde, Assignee

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Opinion Summary
AI Abstract

Doe v. Hyde, Assignee was a United States Supreme Court case that addressed the issue of whether a debtor could be held liable for a debt that was assigned to another party. The case involved a dispute between John Doe and William Hyde, who had been assigned a debt that Doe had previously owed to another party. The Supreme Court held that a debtor cannot be held liable for a debt that has been assigned to another party. The Court reasoned that the assignment of a debt is a transfer of the right to collect the debt, and not a transfer of the debt itself. Therefore, the debtor is not liable for the debt once it has been assigned to another party. The Court also held that the assignee of a debt is not liable for any of the debtor's debts that were not assigned to them. This ruling established the principle that a debtor cannot be held liable for a debt that has been assigned to another party.

Dissent Summary
AI Abstract

Justice Field delivered the dissenting opinion in Doe v. Hyde, Assignee. He argued that the court should have affirmed a decision of the Supreme Court of California which held that an assignment for benefit of creditors was invalid because it had been made without consideration and with intent to defraud creditors. Justice Field reasoned that under California law, such assignments were voidable at any time by either party or their representatives; therefore, as no action had been taken to set aside this particular assignment within four years after its execution, it became valid and binding upon all parties concerned. Furthermore, he noted that even if there was evidence suggesting fraud on behalf of the assignor (the debtor), this did not necessarily render the assignment void ab initio since fraudulent intent must be established beyond reasonable doubt before a contract can be declared null and void due to fraud. Therefore, Justice Field concluded that while fraudulent intent may have existed when making this particular assignment for benefit of creditors, it could not be proven conclusively so as to make it invalid from its inception.

Opinion written by Justice SBlatchford
Decided: Apr 13, 1885
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