Baum Estate

211 A.2d 521, 418 Pa. 404, 1965 Pa. LEXIS 616
CourtSupreme Court of Pennsylvania
DecidedJune 30, 1965
DocketAppeal, 43
StatusPublished
Cited by18 cases

This text of 211 A.2d 521 (Baum Estate) is published on Counsel Stack Legal Research, covering Supreme Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baum Estate, 211 A.2d 521, 418 Pa. 404, 1965 Pa. LEXIS 616 (Pa. 1965).

Opinions

Opinion by

Me. Justice Eobeets,

This appeal involves the validity of charitable bequests contained in a will executed less than 30 days before death. Testatrix died on May 2, 1958, without heirs or next of kin, nine days after executing her last will dated April 23, 1958. In that will, as in her immediately preceding will of September 27, 1955, she bequeathed her residuary estate in equal shares to three designated charities. Both wills were drawn by the same attorney and contained charitable gifts of identical shares of the residue to the same named charitable beneficiaries for the same purpose.

Immediately upon the execution of her will of April 23, 1958, testatrix requested her attorney-scrivener to tear up the signed copy of her earlier 1955 will. This her attorney did, in her presence and in the presence of another person who had witnessed the new will. However, an identical carbon of her 1955 will which had been prepared simultaneously with the revoked signed copy was retained by the attorney.

The Commonwealth, asserting its right as statutory heir under Section 3(6) of the Intestate Act,1 claimed the entire residuary estate for itself, contending that the gifts to the charities contained in testatrix’s last will were of no effect because made within 30 days of testatrix’s death.2

[407]*407The court below held that the undisputed record facts placed the case within the exceptions to the 30-day rule contained in Section 7(1) of the Wills Act,3 [408]*408and established the validity of the charitable gifts. From this determination the Commonwealth appeals.

Section 7(1) of the Wills Act of 1947 creates two methods by which charitable gifts contained in a will executed within thirty days of death may be validated.4 One method permits such charitable gifts if all who would benefit by the invalidity of the charitable bequests agree that they shall be valid. The second method permits such gifts if (a) the probated will revokes a prior will executed at least thirty days before death, (b) “the original of which can be produced in legible condition”, and (c) the prior instrument contains identical gifts for substantially the same charitable purposes. It is undisputed that conditions (a) and (c) have been fulfilled in this case. The crucial issue is whether the carbon sheets of the prior will qualify as an “original” under requirement (b) above or whether, as the Commonwealth contends, only the now-[409]*409destroyed, executed ribbon copy of the prior will can be admitted to prove pre-existing charitable intent.

It is unquestioned that the carbon sheets of the prior will, which, in this case, were retained by testatrix’s attorney and offered to prove the continuing charitable intention of testatrix, were made at the same time, by the same typewriter and by the same strokes as made the now-destroyed ribbon sheets of that will. In John Wanamaker v. Chase, 81 Pa. Superior Ct. 201, 203 (1923), the court said: “Where several copies of a writing are made at the same time by the same mechanical operation each is to be regarded as an original and is admissible as such [Citing cases and other authority.].” (Emphasis supplied.) Similarly, in Werner v. Hillman Coal & Coke Co., 300 Pa. 256, 264, 150 Atl. 471, 473-74 (1930), involving the question whether certain typewritten papers were copies or originals, the Court quoted with approval a statement in Harmon v. Territory, 15 Okla. 147, 164, 79 Pac. 765, 770 (1905). The quoted passage explained that the Oklahoma court did not believe that “a carbon copy of any longhand transcript of a stenographer’s official notes, made by the stenographer himself at the time he makes the transcript and as a part of that transaction, is a copy in the sense that the word copy is ordinarily used, any more than several books or newspapers printed upon the same press at the same time and from the same type are copies of each other.”

The concept is summarized in Words and Phrases5 which, under the heading “Original Writing”, cites Lewis v. Phillips-Body Pub. Co., 18 Ga. App. 181, 89 S.E. 177 (1916), and Savannah Bank & Trust Co. v. Purvis, 6 Ga. App. 275, 65 S.E. 35 (1809), for the proposition that: “All papers executed by the same stroke upon a typewriter — those written by carbon im[410]*410pressions, as well as the sheet which receives the stroke of the letter from the typewriter — are alike originals, and after the identity of the stroke of the typewriter has been established, any of the manifold copies may be introduced as the original writing in the case.” (Emphasis supplied.) Furthermore, in U.S. Fire Ins. Co. v. L.C. Adam Mercantile Co., 117 Okla. 73, 245 Pac. 885 (1926), the syllabus by the court stated: “A carbon impression of a letter written on a typewriter, made by the same stroke of the keys as the companion impression, is an original.” See also Brenner v. Lesher, 332 Pa. 522, 526, 2 A. 2d 731, 733 (1938); Commonwealth, v. Olitsky, 184 Pa. Superior Ct. 144, 154-55, 133 A. 2d 238, 243-44 (1957).

Although we recognize that what is or is not an “original” may vary according to the situation, it is apparent, nevertheless, that a carbon may qualify, in appropriate circumstances, as an “original”. The fact is that the word “original” is subject to and capable of such varied definitional treatment, see Annot. 65 A.L.R. 2d 342 (1959), that it is utterly impossible to properly determine its meaning in a vacuum. Reference must be made to its legislative context and the purpose and policy which the statutory provision seeks to accomplish.

The purpose of the general thirty day provision of our statute has been stated with consistency. “It was to make reasonably sure that testamentary gifts to religion or charity were the result of deliberate intent of the testator, and were not coerced from him while in weakened physical condition under the influence of the doubts and terrors of impending death.” Paxson’s Estate, 221 Pa. 98, 111, 70 Atl. 280, 285 (1908). Prior to 1947, the Wills Act of 19176 made no provision whatever for validating charitable bequests made within [411]*411thirty days of death. It was held to be unbending in its prohibition of such gifts, even where it was clear that the testamentary intent to make such bequests had existed for more than the thirty day period. See, e.g., Hartman’s Estate (No. 1), 320 Pa. 321, 182 A. 234 (1936) . It is graphically clear that the exceptions set out in Section 7(1) of the Wills Act of 1947 were intended to remedy that situation and to remove from the operation of our thirty day prohibition those cases which did not, in reason, fall within the purpose of the thirty day rule. See McGuigen Estate, 388 Pa. 475, 131 A. 2d 124 (1957); Comments of the Joint State Government Commission,7 Comment to §7(1), 20 P.S. §180.7, pp. 267, 268.

In light of this clear legislative history and purpose, it is obvious that what was sought to be accomplished by the validation requirements involved in this case was a form of proof which would satisfactorily show that the charitable intention of the testatrix existed for more than thirty days. Since the section we are considering is remedial in nature, we have held that it must be liberally construed in order to effectuate its purpose.

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Bluebook (online)
211 A.2d 521, 418 Pa. 404, 1965 Pa. LEXIS 616, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baum-estate-pa-1965.