Summary
The court denied a motion to enter satisfaction of a federal judgment based on a later judgment obtained in New York state court and the defendants’ arrest and imprisonment under execution. It held that the later judgment did not extinguish the original judgment, and that an involuntary discharge from imprisonment under state law did not constitute complete satisfaction warranting vacatur of the federal judgment. The court declined to order a partial or modified satisfaction in summary proceedings.
Topics
Practice areas
Questions Presented
- Whether the judgment recovered in the Court of Common Pleas is a satisfaction of the judgment in this court.
- Whether the arrest and imprisonment of the defendants on the judgment in the Common Pleas constitutes a satisfaction of the judgment in this court.
Holdings
- The judgment in the Common Pleas is not a satisfaction of the judgment in this court.
- Arrest and imprisonment of the defendants without the creditor's consent is not a satisfaction of the judgment in this court; satisfaction must be entire and cannot be partial.
Key quotations
“At law, so long as the body is detained in prison, the creditor cannot resort to the property of the debtor, and the judgment will not be considered a lien as against other creditors.” (at 66)
Factual background
Miller, as plaintiff, sought to foreclose a mortgage on Griswold's real estate. Hill's administrator had obtained a judgment in the Court of Common Pleas and executed against the defendants, resulting in their imprisonment under a state act abolishing imprisonment for debt. Miller argued that such imprisonment was a satisfaction of the judgment in this court.
Procedural history
John B. Miller sought an order to enter satisfaction of a judgment recovered in this court; the judgment in the Court of Common Pleas was alleged to be a satisfaction of the present judgment.