Barton's Estate

49 Pa. D. & C. 273, 1942 Pa. Dist. & Cnty. Dec. LEXIS 386
CourtPennsylvania Orphans' Court, Philadelphia County
DecidedDecember 24, 1942
Docketno. 1318 of 1940
StatusPublished

This text of 49 Pa. D. & C. 273 (Barton's Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barton's Estate, 49 Pa. D. & C. 273, 1942 Pa. Dist. & Cnty. Dec. LEXIS 386 (Pa. Super. Ct. 1942).

Opinion

Van Dusen, P. J.,

Emily Barton in 1882, at the age of 22, when domiciled in Pennsylvania, made a deed of trust to a trust company in Pennsylvania. The trust was to pay the income to herself for life, without liability to creditors, etc., and the principal was given as she should direct by will. If the power of appointment was not exercised the principal at her death was given to her children and their descendants and, in default of children, to her next of kin as if she had died the owner. Thereafter she became domiciled in New Jersey, and died leaving a will probated in New Jersey, in which she gave to the Jefferson Medical College Hospital:

“All the rest, residue and remainder of my estate, real, personal and mixed of whatsoever nature and wheresoever situate, including all lapsed legacies, lapsed bequests, lapsed sums of every nature and kind arising from any and all personal property, sales of real estate held in my residuary estate, principal to pay annuities in case of death and also including the principal of the trust funds over which I am given the power of appointment by the will of Susan R. Barton, deceased, and in execution of any and all powers given to me and contained in the said will of the said decedent . . .”

She did not mention the power which she had under her own deed of trust.

The auditing judge held that the question whether her will exercised the power of appointment was to be determined by the law of the situs of the trust and that this was in Pennsylvania. As the will operated as an exercise of the power in Pennsylvania by virtue of section 11 of the Wills Act of June 7, 1917, P. L. 403, the auditing judge awarded the fund to the residuary legatee under the will. It was asserted that under the law of New Jersey the will of the appointor did not [275]*275exercise the power. Claim for the fund was made by the next of kin who would take in default of appointment, and they filed exceptions to the adjudication.

The A. L. I. Restatement of Conflict of Laws, §288, says:

“If a power to appoint movables by will is created by a will, the question whether it is exercised by a general bequest not specifically mentioning the power is determined by the law of the domicil of the donor of the power at the time of his death.”

The text writers agree that the weight of authority supports this statement: 15 C. J. S. 936; 4 Page on Wills (1941), sec. 1649; 87 U. of P. Law Rev. 403, 417, 422, 425; 38 Harvard Law Rev. 661, 666; Minor on Conflict of Laws, 353, sec. 150; Wharton on Conflict of Laws, 1308, sec, 590(a); Notes by Bigelow to Story’s Conflict of Laws (8th ed.), 650, sec. 473(a) n. (a) ; Goodrich on Conflict of Laws, 458; Beale on Conflict of Laws, sec. 288.1. The rule is supported by the Pennsylvania case of Bingham’s Appeal, 64 Pa. 345. See also Aubert’s Appeal, 109 Pa. 447.

We start with this statement because most of the cases are concerned with powers created by will and because the law with respect to such powers is well settled. The stock reason which is given for the rule is thus stated by Professor Beale (sec. 288.1) :

“The settled doctrine is based upon the view that the donee is acting, as courts have said, as the donor’s hand, and not their own will, in making the appointment; and the donor’s will, as interpreted by the law and usage of his domicil, should be effective.”

This seems to be the reasoning in Bingham’s Appeal, supra.

We suggest that it would be more accurate to say (as the auditing judge in substance has said) that it is the law of the situs of the trust which is effective. In the case of a power created by will, the situs is necessarily at the testator’s domicile, for that is the [276]*276controlling factor in determining the place to probate and administer his will. As the author of the article in the Harvard Law Review says (speaking of the personal as well as real property) :

“First, it must be recognized that the law of the situs, that is, of the territorial sovereign of the jurisdiction in which the property is actually located, passes the title to the property in every case of appointment. For certain purposes, however, that jurisdiction may declare its law to be that the property shall pass according to the law of some other jurisdiction.”

And in note 26 he further says:

“It happens that nearly all the cases on this point will square with the theory that the law of the situs of the personalty governs the exercise of the power by a residuary bequest.”

If this be so, then the same reasons apply to a trust created by deed, and the law of the situs of the trust is equally applicable in such a case. There is a dearth of authority with respect to powers over personal estate created by deed. The case of Harlow et al. v. Duryea et al., 42 R. I. 234, is directly in point, however, and so is the case of Wilmington Trust Co. v. Wilmington Trust Co., 186 Atl. 903. The opinion of the Chancellor of the State of Delaware in the latter case is excellent, but is too long to quote. The substance of the reasoning in each case is that which we have just indicated.

As we have said, the situs of a trust created by will depends upon one factor — the domicile of the testator at the time of his death, which is the place of probate of his will. But the situs of a trust created by deed is not so easy to determine. It may depend on many factors, which are thus enumerated in Harlow v. Duryea, supra (p. 239) :

“. . . the donor was domiciled in Massachusetts, the contract was made there, the trust fund was located in Massachusetts, and was to be administered in that state by a Massachusetts corporation.”

[277]*277All these factors are present in the case at bar, as the auditing judge notes. There is also present here the factor that the donee of the power was then a resident of the same State, though she afterward moved away. The same factors are enumerated in Russell v. Joys, 227 Mass. 263, though that case might have been rested on the consideration that the trust res was real estate. In the Wilmington case the whole trust was moved to Delaware, but it was held that the law of New York, under which it was created, followed it.

We, therefore, conclude that the situs of the trust was in Pennsylvania, and that it is the law of Pennsylvania which must determine the application of the will of the appointor, and the question whether a general bequest in such a will operates as an exercise of the power.

Exceptants press upon us section 24 of the Wills Act, supra, which provides:

“Nothing in this act contained shall be construed to apply to the disposition of personal estate by a testator whose domicile at the time of his death was out of this Commonwealth.”

This section is taken from section 17 of the Wills Act of April 8, 1833, P. L. 249. A similar provision is found in section 25 of the Intestate Act of June 7,1917, P. L. 429, which was taken from section 20 of the Intestate Act of April 8, 1833, P. L. 315. The Wills Act of 1833 contained nothing equivalent to section 11 of the Wills Act of 1917. That section is derived from the Act of June 4, 1879, P. L. 88. But now that section 11 is found in the same statute as section 24, the latter section appears to apply to it as well as to the rest of the statute.

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Related

Jackson's Estate
12 A.2d 338 (Supreme Court of Pennsylvania, 1940)
Provident Trust Co. of Phila. v. Scott
6 A.2d 814 (Supreme Court of Pennsylvania, 1939)
Bingham's Appeal
64 Pa. 345 (Supreme Court of Pennsylvania, 1870)
Aubert's Appeal
1 A. 336 (Supreme Court of Pennsylvania, 1885)
Safe Deposit & Trust Co. v. Friend
50 A. 995 (Supreme Court of Pennsylvania, 1902)
Russell v. Joys
227 Mass. 263 (Massachusetts Supreme Judicial Court, 1917)
Wilmington Trust Co. v. Wilmington Trust Co.
186 A. 903 (Court of Chancery of Delaware, 1936)

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Bluebook (online)
49 Pa. D. & C. 273, 1942 Pa. Dist. & Cnty. Dec. LEXIS 386, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bartons-estate-paorphctphilad-1942.