Friday, December 27, 2013

Carmen v. Fox Film Corp. case brief

Carmen v. Fox Film Corp. case brief summary
269 F. 928 (1920)

CASE SYNOPSIS
Defendant challenged the decision of the District Court of the United States for the Southern District of New York, which held that contracts entered with plaintiff actress during her minority were voidable under state law and adjudged the contracts as duly rescinded by her.

CASE FACTS
Defendant challenged the decree of the district court, which held that contracts entered with plaintiff actress during her minority were voidable under state law. The district court therefore adjudged the contracts as duly rescinded by plaintiff and issued a permanent injunction in her favor. Plaintiff alleged that the contracts were signed, executed and delivered to her by defendant in the state of New York. Defendant alleged however that the contracts were executed in California, that plaintiff achieved majority at the age of 18 under California law, as opposed to the age of 21 under New York law, and as such defendants argued that her capacity to contract should be determined by the law of the place of performance.

DISCUSSION

  • The court maintained that it was not material whether the contract was breached or voidable as plaintiff improperly misled another film production company into making a contract when she remained contractually bound to defendant. 
  • The court held that a contract dishonestly obtained was a bar to relief in equity. Accordingly the decree was reversed.
CONCLUSION
The decree was reversed because the court determined that plaintiff's conduct entitled her to no equitable relief as she misled a second production company into entering a contract with her by misrepresenting that she was free to make it.

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