Sheehy v. Mandeville & Jamesson
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Sheehy's separate rule about a note expressly accepted as payment was applied in later cases. All eight flagged citations have been read. The Constitution Annotated lists Sheehy as overruled by Mason; Mason's discussion addresses the judgment-and-merger ruling.
8 citations to Sheehy v. Mandeville & Jamesson sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Sheehy v. Mandeville & Jamesson?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Overruled in part
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The Supreme Court disavowed Sheehy's rule permitting a later common-law suit against another partner after judgment on the same joint debt.
Mason v. Eldred · Supreme Court of the United States · filed
The general doctrine maintained in England and the United States may be briefly stated. A judgment against one upon a joint contract of several persons, bars an action against the others, though the latter were dormant partners of the defendant in the original action, and this fact was unknown to the plaintiff when that action was commenced. ... If, therefore, the common law rule were to govern the decision of this case, we should feel obliged, notwithstanding Sheehy v. Mandeville, to hold that the promissorj' note was merged in the judgment of the court of Michigan, and that the judgment would be a bar to the present action.
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Criticized
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The federal circuit court called Sheehy's separate-suit rule difficult to sustain on general principles, while deciding the case on another ground.
Sedam v. Williams · U.S. Circuit Court for the District of Michigan · filed
Sheeley v. Mandeville, 6 Cranch [10 U. S.] 253. ... The first ground was undoubtedly sustained in the ease cited from 6 Cranch, 253 [supra). That case has not been overruled by the supreme court; but it would seem to be impossible to sustain it on general principles.
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