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Michaels Et Al. v. Post, Assignee

• 1874 • 88 U.S. 398 • Waite Court
In Michaels et al. v. Post, Assignee, the United States Supreme Court was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between a husband and wife, and it provided that the husband would pay the wife a certain sum of money in exchange for her relinquishing her right to a portion of his estate. The wife had assigned her rights to the husband's estate to a third party, and the husband had refused to pay the money as agreed. The...Open Case
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Chief Waite Court
Term: 1874
Docket: 85
88 U.S. 398
22 L. Ed. 520
1874 U.S. LEXIS 1381
Argued: Nov 24, 1874

Michaels Et Al. v. Post, Assignee

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Opinion Summary
AI Abstract

In Michaels et al. v. Post, Assignee, the United States Supreme Court was asked to decide whether a contract between two parties was valid and enforceable. The contract in question was between a husband and wife, and it provided that the husband would pay the wife a certain sum of money in exchange for her relinquishing her right to a portion of his estate. The wife had assigned her rights to the husband's estate to a third party, and the husband had refused to pay the money as agreed. The Supreme Court held that the contract was valid and enforceable. The Court reasoned that the wife had the right to assign her rights to the husband's estate, and that the husband had agreed to pay the money in exchange for her relinquishing those rights. The Court also noted that the husband had accepted the benefit of the contract, and thus was obligated to fulfill his part of the agreement. The Court concluded that the contract was valid and enforceable, and that the husband was obligated to pay the money as agreed.

Dissent Summary
AI Abstract

In the case of Michaels et al. v. Post, Assignee, the Supreme Court was tasked with determining whether a judgment against an insolvent debtor should be enforced by his assignee in bankruptcy proceedings. The majority opinion held that such judgments could not be enforced because they were rendered after the date of assignment and thus did not bind the assignee as it had no knowledge or notice of them at the time of assignment. Justice Field dissented from this decision on two grounds: firstly, he argued that if Congress intended to exempt judgments obtained after assignment from enforcement then it would have explicitly stated so; secondly, he noted that allowing creditors to obtain judgments against debtors prior to their assignments would encourage fraud and deceit among debtors who may attempt to avoid paying their debts by transferring assets before any legal action can take place. He concluded that since Congress had made no explicit statement regarding post-assignment judgments being unenforceable in bankruptcy proceedings, they should remain enforceable under existing law and precedent set forth in earlier cases involving similar facts.

Opinion written by Justice NClifford
Decided: Dec 21, 1874
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