Crites & Stamper v. Associated Frozen Food Packers (1951)
Decided: February 21, 1951; Tooze, J.
Source note (2026-10-18):
- Links on this page to
https://static.case.law/or/190/html/0585-01.htmlare an (unofficial Caselaw Access Project copy, retrieved before 2026-10-18; host disallows automated access); no official or otherwise permitted full-text copy was located on 2026-10-18.
Facts and holding
Creditors garnished frozen goods previously assigned to a Washington collection corporation for creditors’ benefit. The Oregon Supreme Court affirmed judgment against the garnishee because the assignee’s failure to qualify under then-applicable foreign-corporation law rendered the assignment unenforceable as to the Oregon property.
Limits and source
The complete opinion, including the affirmance, was retrieved through the public web reader from the linked reproduction. It documents a historical common-law ABC, not today’s supervision requirements or automatic lien clearance.
Good-law status
The complete reporter transcription was additionally retrieved by ordinary curl on 2026-10-17 and corroborates the opinion, court and February 21, 1951 decision date. The original retrieved reproduction remains the attributed source above.
Current ORS 60.704(5), full official chapter retrieved 2026-10-17, says failure of a foreign corporation to obtain authority does not impair the validity of its corporate acts. Subsections (1)–(3) separately restrict maintaining proceedings until qualification. Do not apply the historical assignment-invalidity rule as today’s general corporate rule.
needs_verification; comprehensive later judicial treatment remains unverified despite this verified statutory difference.
oregon · businesses-and-going-concerns
Legal information, not legal advice. Verify current law before relying on this historical decision.