Chappell v. Stewart – Case Brief
Chappell v. Stewart, 82 Md. 323, 33 A. 542 (Md.1896).
Facts: Chappell (P) brought suit against Stewart (D) claiming that Stewart had hired detectives to follow him and monitor his activities. Chappell claimed that Stewart’s wrongful acts caused him great inconvenience and annoyance, interfered with his social and business activities, and damaged his financial credit. Chappell alleged that Stewart intended to continue to have his detectives follow him.
Chappell sought tort damages and injunctive relief to prohibit Stewart from having him followed in the future. Chappell entered a motion for a preliminary injunction. Stewart claimed that Chappell was not entitled to equitable relief because his complaint did not establish a risk of danger or irreparable damage. The trial court dismissed the complaint and Chappell appealed.
Issue: May a party obtain injunctive relief as a remedy regarding a matter affecting his person?
Holding and Rule: No. A party may not obtain injunctive relief as a remedy regarding a matter affecting his person.
The remedy of injunctive relief is rooted in property law. Courts of equity have no jurisdiction in matters limited to criminal or immoral activity which do not affect any right to property. Jurisdiction cannot be maintained if the charge is one that is against the public peace and does not touch the enjoyment of property. We do not intend to express an opinion regarding any action at law that Chappell may have.
See Peevyhouse v. Garland Coal and Mining Co. for a contract law case brief in which it was held that where a breach pertains to a matter merely incidental to the main purpose of the contract, and performance would be disproportionately costly, the proper remedy is the diminution in value.