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Union Trust Company v. Morrison was a case heard by the United States Supreme Court in 1887. The case involved a dispute between the Union Trust Company and the Morrison family over the ownership of certain bonds. The Morrisons had purchased the bonds from the Union Trust Company, but the company later claimed that the bonds had been stolen from them and that the Morrisons had no right to them. The Supreme Court ruled in favor of the Morrisons, finding that the Union Trust Company had failed to prove that the bonds had been stolen. The Court held that the company had not taken reasonable steps to protect the bonds and that the Morrisons had acted in good faith when they purchased them. The Court also found that the company had not provided sufficient evidence to prove that the bonds had been stolen. The Court's decision established that a party claiming ownership of a stolen item must provide sufficient evidence to prove that the item was stolen. It also established that a party who purchases an item in good faith is entitled to keep it, even if the item is later found to have been stolen.
Justice Field delivered the dissenting opinion in Union Trust Company v. Morrison, arguing that the majority's decision was incorrect and should be reversed. He argued that under Missouri law, a mortgagee had no right to redeem property after foreclosure unless they paid off all of the debt associated with it. The majority held that this rule did not apply because there were two mortgages on the same property; however, Justice Field disagreed and stated that if one mortgage is foreclosed upon then any other mortgages become void as well since they are subordinate to the first lienholder. Furthermore, he argued that even though Union Trust Company was not aware of Morrison's prior mortgage when it issued its own loan against his land, this does not change their status as a second lienholder who has no right to redeem after foreclosure by another creditor. Therefore, Justice Field concluded that Union Trust Company could only recover what remained due on its loan from proceeds generated by sale of Morrison's land following foreclosure by St Louis County Bank - nothing more or less than what would have been owed without knowledge of an earlier existing debt secured against said real estate