Northern Commercial Co. v. E. J. Hermann Co.

Reed, A.C.J.

(concurring) — I concur in the result reached by the majority. However, I have serious reservations about *974the utility of the rather lengthy discourse on "equitable liens." In particular, I believe the specific! security interest in real property which was awarded to Mrs. Hermann in the divorce decree is not an equitable lien and should not be confused with such liens, which are sui generis in this state. See Farrow v. Ostrom, 16 Wn.2d 547, 133 P.2d 974 (1943); Nelson v. Nelson Neal Lumber Co., 171 Wash. 55, 17 P.2d 626 (1932); 4 S. Symons, A Treatise on Equity Jurisprudence §§ 1233, 1235 (5th ed. 1941); 51 Am. Jur. 2d Liens § 66 (1970).

A recognition of the true nature of equitable liens renders unnecessary the effort to distinguish Mrs. Hermann's security interest from the common judgment lien. All we need determine here is that Mrs. Hermann retains some interest in the former community real estate after the decree. It matters not to the community creditors what that interest is, because nothing husband and wife can do or the divorce decree does for them, can derogate against the creditor's right to subject former community property to satisfaction of his valid claims. Farrow v. Ostrom, supra. See also Cross, The Community Property Law in Washington, 49 Wash. L. Rev. 729, 841 (1974).

So long as the creditor affords the former spouses procedural due process, both in obtaining judgment against the former marital community and in executing upon the former community property, neither spouse may complain. In this sense the mechanics differ little, if at all, from any proceeding in rem or quasi in rem.

I should also like to point out that much of the confusion in this case arises because of the failure of Mrs. Hermann to take steps to enjoin a sale of the Mason County property until the character of the debt underlying the judgment had been judicially determined. This she could have done as soon as she was apprised of the judgment by NC which purported to join her as a joint debtor. My observation in this regard is probably academic, however, because the trial court exercised its discretion in permitting her to attack the validity of the judgment. In any event, her petition to *975vacate was denied, the relief granted being only that her interest had not passed under the sale.

In addition, I feel somewhat uncomfortable about the use of language by the majority which might lead one to conclude that a community creditor can somehow proceed against the noncontracting spouse individually and obtain a personal judgment. I am sure this is not what was intended; however, the problem is compounded by NC's misguided attempts to utilize the provisions of RCW 4.68.010 and CR 20(d) to bind Bernadine as a "joint debtor." Clearly, if NC's debt was contracted by Mr. Hermann for himself and for the marital community, his actions without more could not make Bernadine separately liable; thus she could not be a "debtor" in any sense of the word. As noted above, she would simply have an interest in former community property which would be subject to sale to satisfy the former community creditors if due process were followed.

Except for these observations, I concur in the majority's resolution of the principal issue addressed, i.e., whether Mrs. Hermann had an interest in the Mason County property which was not validly sold because she was not afforded due process.