Tuesday, March 5, 2013

Maynard v. Hill case brief

Maynard v. Hill case brief summary
125 U.S. 190 (1887)

SYNOPSIS: Plaintiff heirs challenged an order from the Supreme Court of the Territory of Washington, which affirmed the lower court's order sustaining the demurrer of defendant patent holders and dismissing the heirs' action in equity to charge the patent holders as trustees of certain lands and to compel a conveyance of those lands.

FACTS: The father left the family and moved to Washington Territory where he obtained a legislative divorce.
-Prior to the divorce, he received a land grant.
-After his divorce, the father remarried.
-The land office awarded one half of the land to the father and the other half to the first wife; however, the award to the first wife was cancelled on the ground that at the time of the divorce, the father possessed only an inchoate interest in the land.
-The land was treated as public land, and the patent holders obtained the right to it.
-The heirs claimed that they were the equitable owners of the land, but the territory courts dismissed the complaint on the ground that it did not state a sufficient cause of action.

On further appeal, the Supreme Court of the United States affirmed, holding first that the legislative divorce was valid.

The first wife's lack of knowledge of the legislation did not affect its validity if it was within the competency of the legislature. At the time of the divorce, the father only had a possessory right to the land because he had not yet occupied it for the statutory period of time. Thus, the first wife had no interest greater than that of the father.

OUTCOME: The Court affirmed the order of the territory supreme court.

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