Holt v. Henley, 232 U.S. 637 (1914)

Holt v. Henley

No. 229

Argued March 5, 1914
Decided March 1, 1914
232 U.S. 637

APPEAL FROM THE CIRCUIT COURT OF APPEALS

FOR THE FOURTH CIRCUIT

Syllabus

The amendment to the Bankruptcy Act of June 25, 1910, giving the trustee, as to all property coming into the custody of the Bankruptcy Court, the rights of a creditor holding a lien should not be construed to impair then-existing rights.

Whether the power of Congress is limited in that respect or not, the usual interpretation of such statutes is to confine their effect to property rights subsequently established.

The right of one who had sold to the bankrupt under an agreement to retain title until payment, as it existed on June 25, 1910, was not affected by the amendment to the Bankruptcy Act of that date even if he did not comply with the statutes of the state in regard to recording the agreement.

The goods in this case having been old on conditional sale prior to the amendment of June 25, 1910, the seller had a better title than the trustee. York Manufacturing Co. v. Cassell, 201 U.S. 344.

Where the addition to the premises covered by the mortgage is not in its nature an essential indispensable part of the completed structure contemplated by that instrument, and its removal would not affect the integrity of that structure, the mortgagee takes just such interest in the addition as the mortgagor acquired -- no more, no less.

A sprinkler plant placed on mortgaged premises after the execution of that instrument and under an unrecorded conditional sale agreement held not to have attached to the freehold or to be covered by the after-acquired property clause beyond the extent which the mortgagor had acquired.

193 F. 1020 reversed.

The facts, which involve the relative rights of the trustee in bankruptcy, the mortgagee, and the original owner of a sprinkling plant placed on the property of the bankrupt subsequent to the making of the mortgage under an agreement of conditional sale, are stated in the opinion.