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 A TREATISE

 

ON THE

 

PRINCIPLES OF PLEADING

 

IN CIVIL ACTIONS:

 

COMPRISING

 

A SUMMARY VIEW OF THE WHOLE

 

PROCEEDINGS IN A SUIT AT LAW.

 

BY HENRY JOHN STEPHEN,

SERGEANT AT LAW.

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. . . . Res antiquĉ laudis et artis

Ingredior, sanctos ausus recludere fontes.--Vide.

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THIRD AMERICAN

FROM THE SECOND LONDON EDITION:

WITH A PREFACE, AN INTRODUCTION, A DISSERTATION ON PARTIES

TO ACTIONS, AND NOTES.

BY SAMUEL TYLER, LL. D.,

PROFESSOR IN THE LAW DEPARTMENT OF COLUMBIAN COLLEGE,

 WASHINGTON, D. C., AND AUTHOR OF THE MARYLAND SIMPLIFIED PLEADING,

 ETC., ETC.

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WASHINGTON, D. C.:

WALTER C. MORRISON,

LAW-BOOK PUBLISHER AND SELLER.

1882.

 

Copyright, 1871, by W. H. & 0. H. MORRISON.

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Copyright, 1898, by WALTER C. MORRISON.

 

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Entered according to the Act of Congress, in the year 1871, by

 

 W. H. & O. H. MORRISON,

 

In the Office of the Librarian of Congress at Washington, D. C.

 

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Page v

 

PREFACE.

Stephen on Pleading is one of the great works in English law. Common-law pleading stands forth in it in its finished form. It places Mr. Stephen in the foremost rank of juridical thinkers. Besides its theoretic excellence, exhibiting the principles of pleading cohering in a logical system, the work is rendered eminently practical by introducing a summary and connected account of the whole proceedings in a suit, in which the end that pleading subserves in litigation, and the forms through which it works, are distinctly presented. This edition of the work has been prepared especially for American students of law. It is, nevertheless, as will be present'y seen, the best edition for the practicing lawyer.

In the year 1824 Mr. Stephen published the first edition of his work. In the year 1827 he published the second edition; and in the advertisement to that edition says: "This work, as its title imports, is in its main design elementary and institutional, and intended for the use rather of those who are exploring the principles, than of those who are engaged in the practice of pleading. But us there is reason to believe that it has proved in some measure acceptable to the latter class of readers also, the author has endeavored to adapt it better to their purposes, by introducing into this second edition some additional matter of a practical kind. This is contained, however, for the most part, in notes at the foot of the page, and does not at all derange or in any degree affect the original plan of the work.

"With the same view the index has been considerably enlarged and a table of cases prefixed."

In this second edition Mr. Stephen gave his matured view of the system of common-law pleading, and never attempted to do anything more towards making it more complete.

In the year 1828, the next year after the publication of this second edition of Mr. Stephen's book, the British government appointed a commission of eminent lawyers, amongst whom was Mr. Stephen, to inquire into the practice and proceedings in the superior courts of common law. These commissioners made a report in the year 1833, recommending important changes in the system of pleading; and by acts 3 and 4 Will. IV. c. 42, power was given to the judges at Westminster to carry into effect the recommendations of the commissioners. Great changes in the forms of pleadings were accordingly effected by the pleading rules of Hilary Term, 1834, passed by the judges.

In the next year, 1835, Mr. Stephen published a third edition of his book, conformed to the requirements of the pleading rules of Hilary Term, 1834; and other editions, conformed to the same rules, were published in 1838, 1843, and 1860. And all the editions published in the United States since the year 1831, when the second edition was published in this country, are reprints of these expurgated editions, and are, and have always been, inapplicable to the practice of American courts, and unfit for the American student. And what detracts still more from these editions is, that in the year 1850 the British government appointed another commission of law reformers, and upon their recommendations statutes were passed by Parliament in 1852, 1854, and 1860, called common-law-procedure acts, by which, and the rules of court made under them, much more thorough changes were effected in pleading than those made by the pleading rules of Hilary Term, 1834, which have made all the editions of Stephen on Pleading as inapplicable to the practice of the English courts as the expurgated editions are to the practice of American courts, unless the seventh edition, by Mr. F. F. Finder, published iu 1866, which I have not seen, is conformed to these later reforms.

From the foregoing statement, it is seen that all editions of Stephen on Pleading, except the first and second, are, so far as American courts and American lawyers are concerned, mutilated editions. Therefore it is that the second edition of the book is now reprinted, it being the best manual for law students, and a most efficient guide in the practice of American courts. An introduction, discussing the relative characteristics of the Roman civil law and the common law of England, and pointing out the differences in their respective procedures, has been added, and also a dissertation on parties to actions, for the instruction of students of law. Little else has been added, as this second edition was so fortified by authorities collected by Mr. Stephen himself, that for more than forty years the book has been received as the surest of guides in pleading, both in English and American courts.

The love of innovation induced the State of .Now York, some years ago, to abrogate common-law pleading, and introduce a code of procedure for the regulation of litigation in her courts; and notwithstanding the lamentable confusion and uncertainty, and the greatly increased expense which has thereby been brought into the administration of justice in that State, other States have followed in her track of barbaric empiricism. Mr. Justice Grier has, from the bench of the Supreme Court of the United States, rebuked the folly of abolishing common-law pleading, and substituting the common-sense practice, as it may be called, in its stead. "This system, (says that able judge,) matured by the wisdom of ages, founded on principles of truth and sound reason, has been ruthlessly abolished in many of our States, who have rashly substituted in its place the suggestions of sciolists, who invent new codes and systems of pleading to order. But this attempt to abolish species and establish a single genus is found to be beyond the power of legislative omnipotence. The result of these experiments, so far as they have come to our knowledge, has been to destroy the certainty and simplicity of all pleadings, and to introduce on the record an endless wrangle in writing, perplexing the court, delaying and impeding the administration of justice." This strong condemnation is more than justified by the experience of the New York courts, as may be seen in the chaos of the reports of the code practice in that State. And the evil effects of the code on the administration of law in New York has been signalized in a recent letter from Mr. Charles O'Conor, published in the Albany Law Journal. It is stated in that letter, as the effect of the decisions of the courts, that because of the mixture of law and equity by the code, a case may begin as a common-law case, with a jury impanneled to try it, and if, at the close of the testimony, a case in equity instead of a common-law case, is proved, the judge may dismiss the jury and try the case himself, as chancellor. And the confusion in practice is increased by the want of logical skill in the lawyers trained in the code practice. "All the lawyers (says Mr. O'Conor) who have been admitted to practice in this State for the last twenty years are conversant with the code, and, of course, are not experts in the old common-law practice and pleading. Most of them are entirely ignorant of it, and you may imagine that the code could not easily be displaced by any attempt at reaction. The courts of the United States do not recognize the code, but adhere to the old practice, with its settled distinction between law and equity. This circumstance often leads to much confusion, as you may see illustrated in some reported decisions of the Supreme Court. It is truly laughable, to one conversant with both systems, to see the blunders into which lawyers of great ability, who have come to the bar within the last ten or fifteen years, sometimes fall in framing a declaration, plea, or subsequent pleading at common law in the circuit court of the United States.

"I think the code (continues Mr. O'Conor) contains, as I best recollect at this moment, only one thing which can be called new in principle, and this is an attempt at an absolute impossibility in prescribing the rule of pleading. It declares, in substance and effect, that you shall not plead, as in the old system, the conclusions in law or in reason, from the facts of the case, and at the same time it prohibits you from stating or detailing the evidence merely on which you rely. You are required to state the 'facts' which that evidence conduces to prove. Here, under the name of 'facts,' we find some things required to be stated which are neither, in the vulgar sense of the word, the mere fact, or transaction, or event which did occur, and can be proven by direct evidence, nor the general, rational, or legal conclusions from such fact, transaction, or event.

" Now, according to my conception, it requires somebody much more wise or more subtle than myself, or any special pleader I have ever been acquainted with, to define or find out what it is that should be stated in a regular pleading, drawn in compliance with this requisite of the code. I am not aware that any one has ever attempted to do it. The common practice in this State is, to tell your story precisely as your client tells it to you; just as any old woman, in trouble for the first time, would narrate her grievances; and to annex, by way of schedules, respectively marked A, B, C, &c., copies of any papers or documents that you imagine would help your case. This is most emphatically a fair description of all the pleadings which come from the office of the chief codifier himself. A demurrer to any pleading under the code is a very dangerous step, because it is utterly impossible for the keenest investigator to determine, in most cases, what any other reader than himself will understand to be the import of the pleading, if it be demurred to."

It is at this time especially important that students of law be trained in common-law pleading, and be convinced of its wisdom as a means of administering justice, in order that, as men who influence public opinion, they may, if possible, gradually restore common-law pleading to its former efficiency in the courts. At all events, their training in common-law pleading will enable them, in States where it is abolished, to relieve in some measure the administration of justice from the embarrassments with which it has been environed by codes. For a knowledge of common-law pleading is not only of importance in States whose wisdom has retained it, but also in States where it has been abolished. A machinery of rules and forms is indispensable for an enlightened administration of law, and one familiar with those rules and forms that are applicable to the exigencies of litigation is more capable than one not familiar with them of efficient practice in courts where such machinery is not used.

" Nor are the works of common-law pleading (says Professor Cooley, in the preface to his able edition of Blackstone's Commentaries) superseded by the new codes which have been introduced in so many of the States. A careful study of those works is the very best preparation for the pleader, as well where a code is in force as where the old common-law forms are still adhered to. Any expectation which may have existed that the code was to banish technicality and substitute such simplicity that any man of common understanding was to be competent, without legal training, to present his case in due form of law, has not been realized. After a trial of the code system for many years, its friends must confess, that there is something more than form in the old system of pleading, and that the lawyer who has learned to state his case in logical manner, after the rules laid down by Stephen and Gould, is better prepared to draw a pleading under the node which will stand the test on demurrer than the man who, without that training, undertakes to tell his story to the court as lie might tell it to a neighbor, but who, never having accustomed himself to a strict and logical presentation of the precise facts which constitute the legal cause of action or the legal defense, is in danger of stating so much or so little, or of presenting the facts so inaccurately, as to leave his rights in doubt on his own showing. Let the common-law rules be mastered, and the work under the code will prove easy and simple, and it will speedily be seen that no time has been lost or labor wasted in coming to the new practice by the old road."

Common-law pleading should be simplified, but not abolished. A love of subtlety and of system caused, in the course of time, useless refinements to be ingrafted upon the common-law pleading. But when the system of pleading was fully matured, and what is substantial and what is only incidental could be clearly discriminated from a practical point of view, a process of simplifying it, by cutting off these refinements, was begun in England. No less than twelve statutes, beginning in the reign of Edward III, and coming down to that of George I, had been passed by Parliament before we separated from England, to remedy technical inconveniences. But the system, as we introduced it into this country, had still many over-refinements. And it is because of these mere excrescences that the system became liable to criticism and, in some States, to overthrow. But England, where enlightened opinion has so much influence, has reformed and not destroyed what is as old as her jurisprudence, and has been in all ages deemed an especially wise portion of her law procedure. By the common law procedure acts already mentioned, and the rules of court made under their provisions, pleading has been made as simple as possible, and justice has been thereby administered with entire satisfaction to even the sciolist, who had the vain hope that every litigant could be his own lawyer. But the ancient system of alternate pleadings, eliminating irrelevant facts, and finally evolving the naked question, whether of fact or of law, really in dispute between the parties, and presenting it to the proper tribunal for determination, is retained in all its integrity. The State of Maryland, fourteen years ago, after having from colonial times used the common-law pleading in its most technical form, followed the course of England, and simplified the system, until the old lawyers at first feared that their pleadings, when they had drawn them, were erroneous, because of their simplicity and naturalness. They could not help thinking that something material was left out. It is to be hoped that other States will follow the example of Maryland.

For the common-law-procedure acts, and the rules of court made under their provisions, the reader is referred to Day's Common-Law Acts; Smith's Action at Law, tenth edition; and the 3d vol. Broom & Hadley's Commentaries on the Laws of England, chap. xii.

For the Maryland Simplified Procedure and Pleading, the reader is referred to Tyler's Pleading.

Washington City, January, 1871.

INTRODUCTION for the above book BY SAMUEL TYLER, LL. D.

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