Chase Securities Corp. v. Donaldson, 325 U.S. 304 (1945)

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Chase Securities Corp. v. Donaldson

No. 110

Argued February 27, 1945
Decided May 21, 1945
325 U.S. 304

APPEAL FROM THE SUPREME COURT OF MINNESOTA

Syllabus

1. Upon the record of this suit to recover the purchase price of securities sold in violation of the Minnesota Blue Sky Law and on misrepresentations, the defendant’s immunity from suit cannot be said to have been finally adjudicated by the state courts prior to the legislature’s enactment of an Act which operated to abolish any defense that the defendant may have had under the state statutes of limitations, and the Act therefore did not deprive the defendant of property without due process of law in violation of the Fourteenth Amendment. Following Campbell v. Holt, 115 U.S. 620. P. 310.

2. The essential holding in Campbell v. Holt -- that, where lapse of time has not invested a party with title to real or personal property, a state legislature, consistently with the Fourteenth Amendment, may repeal or extend a statute of limitations, even after right of action is barred thereby, restore to the plaintiff his remedy, and divest the defendant of the statutory bar -- so far as applicable to this case, is sound, and should not be overruled. Pp. 311, 315.

3. The Act in question was a general one, applying to all similarly situated persons or transactions, and did not violate the equal protection clause of the Fourteenth Amendment. P. 309, n. 5.

4. That the defendant had no opportunity to submit testimony of legislators as to the intent of the Act did not constitute a denial of due process of law. P. 309, n. 5.

216 Minn. 269, 13 N.W.2d 1, affirmed.

Appeal from a judgment upholding the constitutionality of a state statute in a suit to recover the purchase price of securities sold to the plaintiff.