Voting Trusts a Chapter in Recent Corporate History

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One of the parties sold his stock, and the vendee sought to vote on it. The other parties sought an injunction restraining the vendee from voting, but the court held that it would not aid the enforce- ment of the contract, as it was a "palpable restraint on the VOTING TRUSTS 123 alienation of property, " although the court admitted that there was nothing per se illegal in the arrangement since it was possibly not so binding as to prevent a with- drawal of deposited stock; in other words, it was... treated really as a case like those decided on the theory of a revocable proxy.
The stock trust of 1877 as to the Pittsburg and Lake Erie Railroad, being expressed in terms to give the trustees a perpetual control of the voting power, was held by the court to be against public policy as depriving the owner of his voting rights; the court assuring the result desired by the plaintiff by holding that, if the position stated was wrong, the agreement at most con- stituted only a revocable proxy {Vanderbilt v.


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