Stateler v. California Nat. Bank

No. 12,155
Decided Circuit Court, N. D. California
Disposition
affirmed
full scope
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Court
Circuit Court, N. D. California
Decided
Judge
MORROW, District Judge
Posture
Contempt proceedings for violation of injunction
Complainant/Agent of the bank (1)
T. K. Stateler
Pierson & Mitchell, Robert Friedrich, of counsel
v.
Defendant/Banking association (1)
California National Bank of San Francisco
Other parties: John Chetwood, Jr. — Respondent/Stockholder, E. G. Knapp — Respondent/Attorney for Chetwood, A. W. Thompson — Respondent/Attorney for Chetwood, W. H. Metson — Attorney for Chetwood, Richard P. Thomas — Former president/director of the bank, Robert R. Thompson — Director of the bank, Robert A. Wilson — Director of the bank, S. P. Young — Receiver of the bank, William K. Vanderslice — Director of the bank, Charles H. Holt — Director of the bank, B. Noyes — Director of the bank, George E. Whitney — Director of the bank

Overview

The court finds respondents John Chetwood, Jr. and E.G. Knapp guilty of contempt for violating the injunction, but imposes only costs as penalties. Respondents must dismiss the writ of error in the Stateler case within 20 days and provide evidence of dismissal. Proceedings against other respondents are dismissed based on their affidavits disclaiming knowledge or participation.

Case summary

This case involves contempt proceedings for violation of an injunction issued in a federal equity action concerning the winding up of an insolvent national bank. T.K. Stateler, elected as agent to succeed the bank's receiver, obtained an injunction restraining stockholder John Chetwood, Jr. and his attorneys from further litigation or attempts to control bank assets. The court found Chetwood and attorney E.G. Knapp guilty of contempt for: (1) applying to state court for attorney's fees from bank funds, (2) using the bank's name in writs of error to the U.S. Supreme Court, and (3) prosecuting a writ of error against Stateler that sought to prevent him from obtaining control of bank assets. The court imposed only costs as penalties, considering mitigating factors including lack of knowledge of the injunction and good faith misunderstandings. The court affirmed its exclusive equity jurisdiction over the receivership proceedings.

Abstract

The case involves contempt proceedings against a stockholder and his attorney for violating a federal equity injunction in the winding up of an insolvent national bank, where they were restrained from further litigation or attempts to control bank assets. Violations included applying to state court for attorney's fees from bank funds, using the bank's name in writs of error to the U.S. Supreme Court, and prosecuting a writ of error to prevent the receiver's successor from obtaining control of assets. The court found them guilty but imposed only costs as penalties due to mitigating factors like lack of knowledge and good faith, affirmed its exclusive equity jurisdiction, ordered dismissal of the writ within 20 days, and dismissed proceedings against others disclaiming involvement.

Opinion of the court

Majority
opinion
MORROW, District Judge
  • Court has exclusive equity jurisdiction over national bank receivership proceedings
  • Injunction properly prohibited further litigation interfering with court's control of bank assets
  • Respondents technically violated injunction but penalties mitigated by circumstances
  • Act of August 13, 1888 does not limit court's power to protect its jurisdiction

Jurisdiction

not challenged
Subject matter
Federal court jurisdiction over national bank receivership and related equity proceedings
Jurisdictional facts
  • Receiver appointed by comptroller of the currency under federal law
  • Receiver submitted to jurisdiction of U.S. circuit court
  • Suit involves interpretation of federal banking laws

Procedural posture

Posture at trial
Contempt proceedings for violation of injunction
Posture on appeal
Direct ruling on contempt charges
Preserved issues
  • Violation of injunction by applying for attorney's fees
  • Violation of injunction by suing out writs of error using bank's name
  • Violation of injunction by prosecuting writ of error against Stateler

Legal categories

Business

Case record

Full case name
STATELER v. CALIFORNIA NAT. BANK OF SAN FRANCISCO et al.
Docket number
No. 12,155
Court
Circuit Court, N. D. California
Trial court
Circuit Court, N. D. California
Trial court judge
MORROW, District Judge
Decided
Opinion author
MORROW, District Judge
Opinion type
published
Precedential status
precedential
Judges on panel
MORROW, District Judge

Issues & holdings

3
Issues raised
3
affirmed
4
Holdings
Standard of review

de novo

Disposition rationale

Technical violation occurred despite subsequent withdrawal

Preservation

Issue preserved for review

Standard of review

de novo

Disposition rationale

Using bank's name in litigation was prohibited by injunction

Preservation

Issue preserved for review

Standard of review

de novo

Disposition rationale

Attempt to control assets through litigation violated injunction

Preservation

Issue preserved for review

Holdings of the court

Contempt for applying for attorney's fees
Chetwood technically guilty of contempt but only costs imposed due to withdrawal after clarification
Action directly violated injunction terms prohibiting settlement of fees from past litigation
unanimousbinding precedent
Contempt for using bank's name in writs of error
Chetwood guilty of contempt for using bank's name in first writ of error
Injunction prohibited further litigation in bank's name; using bank as plaintiff in error violated this
unanimousbinding precedent
Contempt for prosecuting writ of error against Stateler
Chetwood and Knapp guilty of contempt for second writ of error against Stateler
Prosecuting writ that sought to prevent Stateler from obtaining fund violated injunction against attempting control of bank assets
unanimousbinding precedent
Jurisdiction over injunction
Court had authority to issue injunction despite Act of August 13, 1888
Federal court's equity jurisdiction over receiver/agent proceedings is exclusive; statute does not limit court's power to protect its jurisdiction
unanimousbinding precedent

Error analysis

  • Violating injunction by applying for attorney's fees — procedural · error foundNot analyzed as structural violation · not applicable
  • Violating injunction by suing out writs of error — procedural · error foundNot analyzed as structural violation · not applicable

Statutory interpretation

1
Statute
Act of August 13, 1888, section 3
Question
Whether statute permits suits against receiver without court leave, limiting injunction power
Court's reading
Statute does not restrict court's equity jurisdiction to protect receiver/agent proceedings
Canons applied
Plain meaningContextual interpretation

Standards of review

  • Violation of injunction — de novo Court reviews alleged violations of its own injunction order

Timeline

6
Events
2,866
Days, incident to ruling
—
Span
factual eventcited in opinion

Comptroller declares California National Bank insolvent, appoints S.P. Young as receiver

Initiates federal receivership proceedings

Comptroller of currency · S.P. Young
factual eventcited in opinion

Shareholders elect T.K. Stateler as agent to succeed receiver and wind up bank affairs

Stateler becomes de facto agent of bank

Shareholders · T.K. Stateler
filingcited in opinion

Stateler files original action in circuit court to establish agency rights and enjoin further litigation

Initiates the equity proceeding that leads to injunction

T.K. Stateler · California National Bank · John Chetwood, Jr. trial court
rulingcited in opinion

Judge Beatty issues temporary injunction restraining Chetwood and others from further litigation or control of bank assets

Outcome: Injunction granted

Order allegedly violated in contempt proceedings

Judge Beatty · John Chetwood, Jr. · Attorneys trial court
procedural eventcited in opinion

Chetwood applies to state superior court for attorney's fees from $27,500 fund

First alleged violation of injunction

John Chetwood, Jr. · Superior Court trial court
hearingcited in opinion

Contempt hearing before Judge Morrow on orders to show cause

Outcome: Findings of contempt with costs imposed

Court's ruling on contempt charges

Judge Morrow · John Chetwood, Jr. · E.G. Knapp · A.W. Thompson · Attorneys trial court

Facts & evidence

Incident

Location
San Francisco, California

Key facts

7 facts
  1. California National Bank declared insolvent in 1889; receiver S.P. Young appointed
  2. After creditors paid, shareholders elected T.K. Stateler as agent to wind up bank affairs in 1894
  3. Stockholder John Chetwood, Jr. sued directors for negligence in state court, obtained judgment against some directors
  4. Stateler sought control of $27,500 fund from that litigation in state court
  5. Stateler filed suit in federal circuit court to establish his agency rights and enjoin further litigation
  6. Temporary injunction issued February 24, 1896 restraining Chetwood and others from further litigation or control of bank assets
  7. Chetwood and attorneys allegedly violated injunction by: (1) applying for attorney's fees from state court fund, (2) suing out writs of error using bank's name

Procedural history

5 steps
  1. Jan 4, 1896: Stateler files original action in circuit court
  2. Feb 24, 1896: Injunction issued by Judge Beatty
  3. Sept 19, 1896: Chetwood applies for attorney's fees in state court (alleged violation)
  4. Various dates 1896: Chetwood/attorneys seek writs of error to U.S. Supreme Court (alleged violations)
  5. Nov 19, 1896: Contempt hearing and ruling

Evidence in the record

Documentary
  • Injunction order dated February 24, 1896
  • Affidavits from respondents
  • State court records and judgments
  • Writs of error petitions
Challenged
  • Evidence type: Application for attorney's fees in state court · Challenge basis: Violation of injunction · Trial court ruling: excluded · Reasoning: Directly prohibited by injunction terms · Challenged on appeal: false
  • Evidence type: Writs of error using bank's name · Challenge basis: Violation of injunction · Trial court ruling: excluded · Reasoning: Injunction prohibited further litigation in bank's name · Challenged on appeal: false

Sentencing

Sentence imposed
Costs of proceedings
Sentence type
discretionary
Sentencing date
1896-11-19
Sentence challenged on appeal
false

Authorities

Cited authorities (2)

Pettibone v. U.S., 148 U.S. 197
appliedquotedprecedent
Cited for principle that lack of notice of injunction may excuse violation
Parties had not been notified of injunction order
In re Tyler, 149 U.S. 164
followedquotedprecedent
Cited for exclusive jurisdiction of federal court over property in receivership
Property in possession of receiver is in custodia legis and cannot be disturbed without court leave

Statutes

  • Act of August 13, 1888, section 3
  • National banking laws of the United States

Standards & doctrines

  • Custodia legis doctrine
  • Exclusive equity jurisdiction over receiverships

Legal principles applied

  • Property in possession of receiver is in custodia legis and cannot be disturbed without court leave
  • Multiplicity of suits should be prevented
Index terms69
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Judges
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Procedural terms
Entities and documentation
Legal actions
Action type
affirmed
Target
contempt findings
Context
Court finds respondents guilty of contempt for violating injunction
Scope
full
Action type
dismissed
Target
contempt proceedings against Thompson and Vanderslice
Context
Proceedings dismissed based on affidavits disclaiming knowledge or participation
Scope
full
Action type
remanded
Target
writ of error in Stateler case
Context
Respondents ordered to dismiss writ of error within 20 days
Scope
full
Further instructions
Produce evidence of dismissal within 20 days
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