Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Hill v. Snidow
Citations: 100 Cal. App. 2d 37; 222 P.2d 962; 1950 Cal. App. LEXIS 1160Docket: Civ. 17859
Court: California Court of Appeal; October 18, 1950; California; State Appellate Court
Plaintiffs Hayden Hill and his wife appealed a judgment favoring defendants Houston A. Snidow and his wife in a case concerning a financial dispute related to a 17-acre citrus grove. The underlying conflict originated from a June 1945 agreement for the purchase and sale of the grove. After disagreements arose, Snidow filed a quiet title action on April 24, 1947, naming the Hills as defendants. The Hills subsequently filed a separate action for reformation of contract and accounting but later dismissed it. The Hills answered the quiet title action, which was ultimately decided in favor of the Snidows but was reversed on appeal. In December 1948, the Hills initiated the present action, and the Snidows raised an affirmative defense, claiming that the Hills were barred from relitigating matters related to the previous transaction due to the earlier quiet title action. The trial court upheld the Snidows' defense, concluding that the Hills could have sought all necessary relief through a counterclaim in the quiet title case but failed to do so. The court referenced Section 439 of the Code of Civil Procedure, which prohibits parties from splitting their claims across multiple actions. Additionally, the court addressed the issue of a jury trial, concluding that the Hills did not request a jury trial in the current case, although they had moved for one in the quiet title action, which was denied. The judgment was affirmed, the appeal regarding the new trial was dismissed as nonappealable, and the appeal concerning the jury trial was also dismissed due to the absence of a formal request in the current action. Judges Moore and Wilson concurred with the decision.