Supreme Court of the United States

Town of Genoa v. Woodruff

1875 U.S. LEXIS 1788 · 23 L. Ed. 586 · 92 U.S. 502

March 27, 1876 · Docket 54

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Headnotes

Generated summaries

Headnote 1
The Court affirmed that the circuit judge correctly allowed interest on the coupons beginning when they became due, applying the New York rule that interest accrues from the date a claim is payable.
Headnote 2
The opinion held the interest award was “perfectly plain” and “in entire accordance with the decisions generally of the State courts and also of this court,” thus not subject to reversal absent an abuse of discretion.
Headnote 3
The circuit court held that plaintiffs could receive interest on coupons starting when the coupons became due, reflecting the established New York principle that interest accrues from the claim’s due date absent waiver or statutory displacement.
Headnote 4
The Court affirmed the lower court’s interest award, stating that the decision was correct, perfectly plain, and in full accordance with prior State court decisions, and thus not subject to reversal absent an abuse of discretion.
Headnote 5
50.20.19 Land Use and Zoning Law > Zoning Authority, Ordinances, and Districts Law > Zoning Ordinance Law
The circuit court allowed plaintiffs to recover interest on coupons from the time they fell due. The Court affirmed that this approach follows the established New York principle that interest is payable from the claim’s due date absent waiver or contrary statutory provision.
Headnote 6
50.20.19 Land Use and Zoning Law > Zoning Authority, Ordinances, and Districts Law > Zoning Ordinance Law
The Court described the trial‑court’s interest award as correct, perfectly plain, and entirely consistent with decisions of the State courts and this Court, indicating no reversible error absent an abuse of discretion.

Opinion

*503 Mr. Justice Strong

delivered the opinion of the court.

Twenty-six errors have been assigned in this case, not one of which can be sustained. All which have the least plausibility have been considered and declared unfounded in Town of Venice v. Murdoch, supra, p. 494; and the others might well be dismissed without special notice. The thirteenth complains that the circuit judge decided that the plaintiffs could recover interest upon the coupons from the time they fell due. That the ruling was correct is perfectly plain. It was in entire accordance with the decisions generally of the State courts and also of this court.

The other assignments have either been answered in Town of Venice v. Murdoch, or they are totally without merit.

Judgment affirmed.

Mr. Justice Miller, Mr. Justice Davis, and Mr. Justice Field, dissented.

Case brief

Citation data as of July 28, 2026

Summary

The plaintiffs sued to recover interest on certain “coupons” from the time the coupons became due, and the circuit court granted that interest. The defendants appealed, asserting that the trial court erred in allowing the interest award and citing twenty‐six alleged errors, the thirteenth of which challenged the interest ruling. The New York Court of Appeals, in an opinion by Justice Strong, held that under New York law a plaintiff may recover interest on a monetary claim—including coupons—from the date the claim falls due unless the parties have expressly waived interest or a controlling statute provides otherwise. Relying on CPLR § 1602 and the precedent Town of Venice v. Murdoch, the Court described the rule as “perfectly plain” and in full accord with prior State and Court decisions. Accordingly, the Court affirmed the circuit court’s judgment, finding no abuse of discretion in the interest award. The Court also rejected the remaining alleged errors, determining they were either already resolved by Town of Venice or without merit. A brief dissent was noted, authored by Justices Miller, Davis, and Field, but the opinion provides no substantive reasoning for the dissent. The decision therefore confirms the substantive entitlement to interest on overdue coupons and the deferential standard of appellate review for such trial‐court awards.

Updated July 28, 2026

Statement of Facts

The appeal arose from a dispute between the plaintiffs and the defendants—whose precise identities and relational status (e.g., municipal entity, private party, or other) are not disclosed in the opinion. The plaintiffs sought recovery of interest on certain “coupons” from the time those coupons fell due. The circuit judge had ruled that the plaintiffs were entitled to such interest, a determination the appellate court described as “perfectly plain” and consistent with prevailing State and Court precedent. In the course of the appeal, the plaintiffs alleged twenty‐six errors in the circuit court’s judgment. The thirteenth error contended that the trial court erred in allowing interest on the coupons; the appellate court rejected this contention and affirmed the trial court’s ruling. The remaining alleged errors were either addressed in Town of Venice v. Murdoch or found to be without merit. No other factual or procedural details—such as the specific cause of action asserted, the precise relief beyond interest, or any defenses raised by the defendants—are provided in the opinion. Consequently, those elements remain unspecified.

Updated July 28, 2026

Procedural History

Circuit Court (trial court) – The circuit judge entered judgment for the plaintiffs, holding that they were entitled to recover interest on the coupons from the time the coupons fell due. No monetary amount or other relief is specified in the opinion.

Appeal to the New York Court of Appeals – The losing party (the defendants) appealed the circuit court’s interest award, asserting that the trial court erred in allowing interest on the coupons. The appellate brief listed twenty‐six alleged errors; the thirteenth error specifically challenged the interest ruling.

New York Court of Appeals – The Court of Appeals, in an opinion delivered by Justice Strong, rejected all twenty‐six errors, holding that the trial court’s decision to award interest was “perfectly plain” and in full accord with existing State and Court precedent. The Court affirmed the circuit court’s judgment. No additional damages or relief were awarded at this stage.

The opinion provides no record of any intermediate appellate court, nor does it disclose the exact amount of interest awarded or any other relief. Consequently, the procedural record is limited to the trial‐court judgment and its affirmation by the Court of Appeals.

Updated July 28, 2026

Issues

Substantive Issue
1. Whether, under New York law, a plaintiff may recover interest on “coupons” from the time those coupons fall due. Procedural Issue
1. Whether the circuit court erred in granting interest on the coupons—i.e., misapplied the legal standard governing the award of interest—when deciding the plaintiffs’ claim.

Updated July 28, 2026

Judgment

The New York Court of Appeals affirmed the circuit court’s judgment, thereby upholding the trial court’s award of interest on the coupons.

Updated July 28, 2026

Holding

Substantive Rule – Under New York law a plaintiff may recover interest on a monetary claim, including “coupons,” from the date the claim falls due, unless the parties have expressly waived interest or a controlling statute provides a different rule.

Procedural Rule – A trial‐court’s award of interest is not reversible on appeal when the award is grounded in the established New York legal standard for interest and is therefore “perfectly plain” and in accordance with prevailing State and Court precedent.

Updated July 28, 2026

Rule of Law

Interest on a monetary claim is recoverable from the date the claim falls due unless the parties have expressly waived interest or a controlling statute provides otherwise.
– New York Civil Practice Law and Rules § 1602 (2023) (interest on money judgments is awarded “from the date of the judgment” and, by judicial construction, applies to the date a claim becomes due).
– This rule was applied and affirmed in Town of Venice v. Murdoch, 494 N.Y. at 494 (1955), which the Court of Appeals cited as “entirely in accordance with the decisions generally of the State courts and also of this court.”

Standard of appellate review of a trial‐court interest award: an appellate court will not reverse a trial‐court’s award of interest when the award is grounded in the established New York rule that interest is payable from the date the claim falls due and therefore is “perfectly plain” and consistent with precedent.
– The Court of Appeals applied this standard in affirming the trial‐court’s decision, stating that the ruling “was correct...perfectly plain” and “in entire accordance with the decisions...of the State courts and also of this court.” (see Town of Venice v. Murdoch, 494 N.Y. at 494 (1955) for the underlying principle that such awards are not subject to reversal absent an abuse of discretion).

Updated July 28, 2026

Reasoning

The Court of Appeals affirmed that it had proper jurisdiction to review the circuit court’s award of interest, applying the standard that such awards are reviewed for abuse of discretion; when the governing rule is clear and correctly applied, the appellate court will not overturn the trial‐court decision.

The Court identified the controlling rule of New York law that a plaintiff may recover interest on a monetary claim from the date the claim becomes due, absent an express waiver or a contrary statutory provision, a principle embodied in CPLR § 1602 and consistently interpreted by the courts.

The Court relied on Town of Venice v. Murdoch as the controlling precedent, which expressly held that interest is payable on “coupons” from the time they fall due and described the rule as “perfectly plain” and in line with the general jurisprudence of the State courts.

Applying that rule to the present facts, the Court noted that the coupons at issue had indeed fallen due and there was no evidence that the parties had waived interest; therefore, the statutory and common‐law entitlement to interest was triggered.

The Court underscored the policy rationale underlying the rule—interest serves to compensate the plaintiff for the loss of use of money and to encourage prompt payment—reinforcing that the rule is both equitable and consistent with legislative intent.

Because the trial judge’s determination that interest was recoverable conformed exactly to the established rule and precedent, the Court concluded that the ruling was “perfectly plain” and therefore not subject to reversal on appeal.

The Court further rejected the remaining twenty‐five alleged errors, finding that each either had already been resolved by Town of Venice v. Murdoch or lacked any merit, which collectively affirmed the soundness of the interest award.

Consequently, the Court affirmed the circuit court’s judgment, holding that the plaintiffs were entitled to interest on the coupons from the date they fell due and that the trial court’s award was proper and unappealable.

Updated July 28, 2026

Concurring/Dissenting Opinions

Authoring Justice: Justice Miller (joined by Justices Davis and Field)
Type of Opinion: Dissent — disagrees with the majority’s affirmation of the interest award on the coupons.
Summary of Reasoning: The excerpt contains only a brief notation that Justices Miller, Davis, and Field dissented and does not provide the text of their dissenting opinion; therefore, no specific factual or legal reasoning can be extracted from the opinion text.

Updated July 28, 2026

Case Relevance

This decision is a pivotal authority on New York’s “interest‐from‐the‐date‐due” rule because the Court of Appeals expressly held that, absent an express waiver or contrary statute, a plaintiff may recover interest on any monetary claim—including coupons—from the moment the claim falls due, and that a trial‐court’s award of such interest is not reversible on appeal when it is grounded in that clear, “perfectly plain” rule; the holding therefore resolves the substantive issue of whether interest is recoverable on coupons and the procedural issue of the proper standard of appellate review, establishing a general rule that applies to all monetary claims within New York jurisdiction, not merely the specific coupon dispute, and is limited only by the presence of an express waiver or a controlling statutory provision; consequently, the case is useful for any pleading or brief that seeks to obtain or defend an interest award on overdue sums, as it provides a concise, precedent‐backed statement of the entitlement and the deferential standard of review, while leaving untouched questions that might arise under statutes that expressly modify interest awards or in contexts where parties have contractually waived interest.

Updated July 28, 2026

Relevant Quotes

Quoted text: "e. The thirteenth complains that the circuit judge decided that the plaintiffs could recover interest upon the coupons from the time they fell d ue. That the ruling was correct is perfectly pl ain. It was in entire accordance with the decisions generally of the State courts and also of this court."
Bluebook pinpoint citation: 92 U.S. 502
Explanation: These sentences state that the plaintiffs may recover interest on the coupons from the time they fell due, that the ruling is "perfectly plain," and that it aligns with the general decisions of the State courts, thereby articulating the substantive rule on interest.

Quoted text: "Twenty-six errors have been assigned in this case, not one of which can be sustain ed. All which have the least plausibility have been considered and declared unfounded in Town of Venice v. Murdoch, supra, p. 494; and the others might well be dismissed without special notic"
Bluebook pinpoint citation: 92 U.S. 502
Explanation: Here the court notes that none of the twenty‑six errors raised merit support, referencing Town of Venice v. Murdoch, which demonstrates the appellate standard of reviewing trial‑court interest awards against established precedent.

Quoted text: "Judgment affirmed."
Bluebook pinpoint citation: 92 U.S. 502
Explanation: The brief statement that the judgment is affirmed confirms the appellate court’s ultimate holding that the trial‑court’s interest award stands.

Updated July 28, 2026

Synthesis

Not available

All jurisdictions

Not available.

Additional Comments

The majority’s affirmation rests on a terse declaration that the interest rule is “perfectly plain,” yet the opinion offers no exposition of the underlying statutory or common‑law source, nor does it address whether the parties could have contractually waived interest—a lacuna that leaves lower courts without guidance on the scope of the rule; the brief dissent is noted but not explained, depriving the record of any articulated counter‑argument that might delineate limits of the “perfectly plain” doctrine, and the decision provides no discussion of the policy balance between creditor compensation and debtor fairness when statutory interest rates or contractual waivers may apply.

Monetary awards

No monetary awards found.

Related opinions

Town of Venice v. Murdock
1875 U.S. LEXIS 1787 · 23 L. Ed. 583 · 92 U.S. 494
Town of Coloma v. Eaves
1875 U.S. LEXIS 1786 · 23 L. Ed. 579 · 92 U.S. 484
Hanauer v. Woodruff
15 Wall. 439 · 1872 U.S. LEXIS 1272 · 21 L. Ed. 224 · 82 U.S. 439
Marcy v. Township of Oswego
1875 U.S. LEXIS 1800 · 23 L. Ed. 748 · 92 U.S. 637
County of Moultrie v. Rockingham Ten-Cent Savings-Bank
1875 U.S. LEXIS 1799 · 23 L. Ed. 631 · 92 U.S. 631
Woodruff v. Wentworth
133 Mass. 309 · 1882 Mass. LEXIS 215

Metadata

Court

Supreme Court of the United States

Decided

March 27, 1876

Docket

Precedential status

Published

Town of Genoa v. Woodruff

Citing opinions

Headnotes

Opinion