Bool v. Bool

165 Ohio St. (N.S.) 262
CourtOhio Supreme Court
DecidedMay 23, 1956
DocketNo. 34518
StatusPublished

This text of 165 Ohio St. (N.S.) 262 (Bool v. Bool) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bool v. Bool, 165 Ohio St. (N.S.) 262 (Ohio 1956).

Opinion

Stewart, J.

This cause was ably briefed and argued in this court by counsel for all parties, and in the brief of Anne Elizabeth Bool there is a succinct summary of facts and issues which all agree is accurate. That summary is as follows:

“By item IV of his will, executed August 4, 1948, Samuel E. Bool gave to his daughter the residue of his estate [approximately $1,000,000] except ‘any stock or securities which I may own issued by the Mather Iron Company.’ By item V he bequeathed in trust such ‘stock or securities.’

“Mr. Bool had owned 5,004 shares of class A preferred stock of Mather Iron Company. These shares were redeemed on March 31, 1953, by appropriate corporate action all of which was duly taken [by deposit in the Cleveland Trust Company of $100 per share].

“Mr. Bool died on December 4, 1953. The certificates evidencing the redeemed shares were among his effects.

[267]*267“The question is whether the daughter or the trustee is entitled to the proceeds of the redemption of the shares.”

Even if the trustee is entitled to the proceeds of the shares, the income from that trust as well as some of the principal, if needed, is to be paid to the daughter during her lifetime, and, if, when she dies, she leaves children, either natural or adopted, or their lineal descendants, such persons inherit the entire trust estate. It is only in case the daughter dies without natural or adopted children or their lineal descendants that the charities become the beneficiaries of the trust.

There seems to be no question that if the bequest of “any stock or securities which I may own issued by the Mather Iron Company” was adeemed before testator’s death, then the proceeds of the stock must be distributed to Anne Elizabeth Bool as part of the residuary estate, whereas if the stock or securities were not adeemed, the trustee is entitled to the proceeds.

Ademption is derived from the Latin word, “ademptio,” which means “a taking away.”

There are two kinds of ademption, one, by satisfaction of a legacy, sometimes known as the ademption of a general bequest, and, two, by its extinction, which has reference to a specific bequest.

Ademption by satisfaction occurs in consequence of some act of the testator in his lifetime which, though not directly a revocation of the bequest, is considered in law as equivalent thereto or indicative of an intention to revoke.

The question of ademption of a general legacy depends entirely upon the intention of the testator as inferred from his acts under the rules established in law. Cowles, Exr., v. Cowles, 56 Conn., 240, 13 A., 414; Richards v. Humphreys, Exr. (Chief Justice Shaw), 32 Mass., 133.

Thus, where there has been a bequest for a particular purpose and money is advanced by the testator in his lifetime for the same purpose, the legacy is considered to be adeemed. Richards v. Humphreys, supra.

The ademption of a specific legacy is effected by the extinction of the thing or fund, as it is generally stated, without regard to the testator’s intention.

This has been quite generally the holding of the courts [268]*268since the case of Stanley v. Potter (1789), 2 Cox. Ch., 180, in which case it was said that a bequest of a debt is adeemed by the debt being paid to the testator in his lifetime whether the payment be compulsory or voluntary. And Lord Thurlow added, “and I do not think that the question in these cases turns on the intention of the testator.”

If a testator bequeaths a specific horse to a legatee and that horse dies while the testator is living, the legacy is adeemed and the legatee has no claim to either another horse or the money equalling the value of the horse that died.

In the present case we have no question that the bequest of the ‘ ‘ stock or securities which I may own issued by the Mather Iron Company” constitutes a specific bequest, and we must determine whether it was adeemed by the redemption of the 5,004 shares of the class A preferred stock under the company’s articles of incorporation by which it had the right to redeem.

It is the contention of Anne Elizabeth Bool that at the time of his death her father owned no stock in the Mather Iron Company but was merely the owner of the money which had been deposited in the Cleveland Trust Company for the redemption of his stock; that the stock certificates which her father owned were not the stock, the certificates evidencing stock ownership only and being evidence of the shareholder’s property interest in the corporation; that, since, under the articles of incorporation, the Mather Iron Company had the right to redeem and call in the stock certificates by depositing $100 per share and accrued dividends with a bank or trust company, and since it had redeemed the stock by the deposit, in accordance with such articles, the shareholder, after the redemption had been made, was no longer the owner of any stock but had only a right to receive the deposit of money made therefor; and that, since the Mather Iron Company had become thereby the owner of the stock, with the right to reissue it if it so desired, testator’s stock was extinguished during his lifetime and thereby the bequest of it as a specific legacy was adeemed.

This argument would be persuasive and would present an entirely different question from the one we have before us were the bequest only of stock in the Mather Iron Company. Since all necessary steps to redeem such stock and extinguish testa[269]*269tor’s ownership were taken, leaving to him in his lifetime only a right to the money deposit that had been made for the stock, it would seem that testator no longer owned the stock in the Mather Iron Company at the time of his death. If he had collected the deposit during his lifetime and made no other provision in his will, undoubtedly the proceeds of the stock would perforce become a part of his residuary estate, and Anne Elizabeth Bool would be the absolute owner of it. However, testator had not collected the proceeds in his lifetime. The stock certificates were found among his effects, and the deposit made by the Mather Iron Company to redeem the stock was still held by the Cleveland Trust Company.

It must be remembered that the bequest was “any stock or securities which I may own issued by the Mather Iron Company. ’ ’

Did the testator own securities at his death?

According to the provisions of the articles of incorporation which formed the agreement between testator, as the owner of class A preferred stock, and the corporation, testator had the following rights as a result of his stock ownership:

1. He or his successors should receive dividends at the rate of five per cent per annum, cumulative.

2. The corporation would set aside annually a specific portion of its earnings in a sinking fund for the purpose of retiring preferred stock.

3. Upon liquidation of the corporation testator would be a Xjreferred shareholder, as against shareholders of any other class, to the amount of $100 per share of his stock.

4. In the event the corporation redeemed his stock, it would set aside the redemption price of $100 per share of such stock to be refunded to him.

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Related

Groby v. State
143 N.E. 126 (Ohio Supreme Court, 1924)
Field v. Schieffelin
7 Johns. Ch. 250 (New York Court of Chancery, 1823)
Richards v. Humphreys
32 Mass. 133 (Massachusetts Supreme Judicial Court, 1833)
Cowles v. Cowles
13 A. 414 (Supreme Court of Connecticut, 1888)

Cite This Page — Counsel Stack

Bluebook (online)
165 Ohio St. (N.S.) 262, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bool-v-bool-ohio-1956.