## Facts

- J.R. (plaintiff) sold certain debts to M.P. and J.B. (defendants).
- The debts were **choses in action**, which at the time could not vest in a purchaser in a way that let the purchaser sue to collect them in their own name.
- M.P. and J.B. gave J.R. a **sealed bond** for the purchase price.
- After the sale, M.P. and J.B. learned they could not collect the debts because the legal right to enforce them did not pass to them.
- J.R. sued M.P. and J.B. at common law on the sealed bond to recover the purchase price.
- M.P. and J.B. argued that the bargain was invalid because they received nothing of value, given the inability to enforce the debts.
- The common-law court rejected that argument as a defense to liability on a sealed obligation.
- M.P. and J.B. then sought relief in **Chancery** by subpoena.
- The dispute over equitable relief was argued before both the **King’s Bench** and the **Court of Common Pleas**.
- The court acting in equity ordered J.R. either to bring the bond into Chancery to be cancelled or to grant a release to M.P. and J.B.
- J.R. refused to comply; the court held him in contempt and committed him to jail until he complied.
- J.R. appealed.

## Issues

1. Whether an obligor may defeat an action on a sealed bond at common law by alleging that the underlying bargain provided no value because the purchased debts could not vest in the obligor.
2. Whether equity may relieve obligors from a sealed bond when the subject of the bargain (assigned debts/choses in action) cannot be enforced by the purchasers and is therefore of no use to them.
3. Whether Chancery may compel the obligee to surrender a bond for cancellation or execute a release, and enforce that order through contempt imprisonment.

## Decision

- The common-law court treated the sealed bond as enforceable and held that the defendants’ claim of “no value received” was not a legal defense to a specialty.
- In equity, the court relieved M.P. and J.B. from the bond because the sold debts could not vest in them in an enforceable way and thus were of no use to them.
- The court ordered J.R. to bring the bond into Chancery for cancellation or to grant a release to M.P. and J.B.
- When J.R. refused, the court found him in contempt and jailed him until he complied.
- J.R. appealed the equitable order and contempt commitment.

## Legal Principles

- At common law, a **sealed bond (specialty)** could be enforced even if the obligor asserted that the underlying exchange proved worthless; failure or lack of value was not a defense in the same way it could be for nonsealed promises.
- The nonassignability of **choses in action** at common law could leave a purchaser without an effective means to sue on purchased debts in their own name.
- Equity could grant relief against enforcement of a bond where enforcing it would be unfair because the promised subject matter could not be enjoyed as intended.
- Chancery could act on the person of the obligee by ordering surrender and cancellation of the bond (or a release), and could use **contempt imprisonment** to compel obedience.

## Conclusion

*J.R. v. M.P.* contrasts strict common-law enforcement of sealed obligations with equitable relief aimed at preventing payment for debts that could not be effectively enjoyed by the purchasers, including an order to cancel or release the bond backed by contempt imprisonment when the obligee refused to comply.


J.R. v. M.P., Yearbook, 37 Henry 6, 13, pl. 3. (1459)