Sunday, October 14, 2012

Harris v. Balk (1905) (debt travels with you)


a.       Facts- Harris and Balk are from North Carolina, Epstein is from Maryland. Harris owed money to Balk, and Balk owed money to Epstein. Epstein brought suit in Maryland against Harris (while Harris was in Maryland) for the money owed by Balk, Epstein got his money from Harris, thus resolving the debt between Epstein and Balk…and effectively, resolving debt between Harris and Balk. Balk then brought suit against Harris for the money Harris owed him, even though he paid same to Epstein. Balk claimed that debt was made in North Carolina, so Maryland Ct had no jurisdiction to attach the debt to the Maryland suit
b.      Procedural History- Balk sued Harris, district Ct and N.C. Sup Ct found for Harris
c.       Issue- Whether the situs (location) of the debt is relevant when determining jurisdiction to attach
d.      Holding- No, situs is irrelevant in determining whether a State has jurisdiction to attach said debt to suit
e.       Rule- For jurisdictional purposes, a debt travel with the debtor. Courts may assert jurisdiction over debts, so long as the court has jurisdiction over the person
f.       Rationale- A person’s obligation to pay a debt follows them wherever they go, and a court may exercise jurisdiction over the debt so long as they may exercise jurisdiction over the person
g.      Notes:
                                                  i.      This case considers “debt” to be “property”…therefore this case is quasi in rem
                                                ii.      “debt” not only travels with the debtor…but also with the grantor
                                              iii.      Quasi in rem- MUST be dealing with some type of property…must be somehow connected with the lawsuit

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