Cowden v. Cowden

18 Ohio C.C. Dec. 71, 7 Ohio C.C. (n.s.) 277
CourtMahoning Circuit Court
DecidedOctober 15, 1905
StatusPublished

This text of 18 Ohio C.C. Dec. 71 (Cowden v. Cowden) is published on Counsel Stack Legal Research, covering Mahoning Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cowden v. Cowden, 18 Ohio C.C. Dec. 71, 7 Ohio C.C. (n.s.) 277 (Ohio Super. Ct. 1905).

Opinion

COOK, J.

This action is for the partition of real estate; and the question in dispute between the parties relates to the title of twenty-five acres of The land sought to be aparted.

[72]*72April 17, 1888, Samuel M. Cowden, now deceased, his wife joining with him, executed and delivered to his daughter, Julia C. Lawrence, a deed in fee simple with covenants of general warranty for the twenty-five acres. The consideration expressed in the deed is “one dollar and other considerations herein expressed.” And written upon the margin of the deed is, “Second consideration, the use of a certain lane to get to the residue of the real estate of the grantor.” This so-called second consideration is of no importance in the determination of the questions involved, and we dismiss it without further comment..

At the time of the execution of the deed, the grantor and his wife had several children, who are still living, and the grantee had a husband and two children, who are also still living.

The claim of the plaintiff and the other brothers and sisters of Mrs. Lawrence is, that this deed was made as an advancement upon the part of the father to his daughter, and that she should account in this action for this twenty-five acres in the division or sale of the residue of the real estate, which is about two hundred and ninety acres..

The claims of Mrs. Lawrence are:

First. That it was not an. advancement, — never so intended,— but on the' contrary was an absolute gift upon the part of the father1 to her.

Second. That the consideration expressed in the deed was a valuable one, and that her title came by purchase, and that therefore the other heirs have no interest in the twenty-five acres.

We do not propose to review the evidence, as the conclusion at which we have arrived makes it unnecessary, except to say that we are not informed whether or not the one dollar was paid, there being no evidence upon that question.

If we treat this deed as a deed of gift made upon the consideration of love and affection, the first question that arises is, Upon whom does the burden of proof rest to show whether it was an advancement or not ?

In 1 Am. & Eng. Enc. Law (2 ed.) 765 and 766, the text reads:

“A voluntary conveyance of land from father.to child, expressed in the deed to be in consideration of love and affection, is presumed to be an advancement.
“The same is true of a conveyance to the child by an outside party, the consideration being paid by the father.
“But this presumption is rebuttable.”

The text is supported by many authorities, and' while there are [73]*73some decisions to the contrary, the doctrine of the text seems to be the better holding.

In the case of Tremper v. Barton, 18 Ohio 418, the syllabus reads:

“Where a father purchases and pays for land, and directs the conveyance to be made to one of his children, the presumption of law is, that it is intended as an advancement; but this presumption may be rebutted by proof.”

Although at that time the syllabus was not the law of the case, it is supported by the opinion of Chief Justice Hitchcock, who does not declare it to be a “presumption of law”, as stated in the syllabus but a presumption of fact.

It will be observed, however, that the consideration of this deed does not purport to be for natural love and affection, but for one dollar. Although natural justice to all the children would seem to dictate that the property of the father should be divided equally among them, yet we are fully persuaded from the evidence that he intended Mrs. Lawrence to have the twenty-five acre tract in addition to what she would be entitled to at his death, dying intestate.

The next question is: What effect shall be given to a deed of this character from a father to a daughter that expresses a consideration of one dollar? Is it a deed of gift, or does the grantee take the land by purchase? If a deed of purchase, then no question of “advancement” is involved.

A conveyance upon a valuable consideration, as between the parties and their representatives, makes the conveyance one of purchase, while a deed of gift from an ancestor creates a different estate in the grantee. In the latter case, the land is ancestral property subject to a certain line of descent; in the former it is not ancestral property, and the line of descent is different by statute.

In this case, if it is a deed of gift, in the event of the death of Mrs. Lawrence and the two children before the death of the husband, then the tract of land would go to the husband for life, with remainder to her heirs; if a deed of purchase, the land would go to the husband and his heirs absolutely.

What character of title, then, does a mere nominal consideration of one dollar expressed in the deed, as between the parties and their representatives create in the absence of fraud; and where the rights of third parties are not involved.

There is great contrariety of decisions in the different states upon this question.

In Hatch v. Straight, 3 Conn. 31 [8 Am. Dec. 152], it was held:

[74]*74“A deed from a parent to a child in consideration of love and •affection is presumed to be an advancement. Though this presumption may be rebutted, yet in a deed of lands from a father to a son, in consideration of love and affection, and the further consideration expressed of five dollars, will not be sufficient to rebut the presumption.’”

Chief Justice Hosmer, in the opinion, says:

“This brings me to the principal question in the case, which is, whether anything appears to rebut the presumption of advancement. The deed to Henry A. Straight is expressed to be ‘in consideration of love and affection, and of five dollars. ’ It would be ascribing too much importance to this nominal consideration' to consider it as repelling the proof of advance portion. The principle of equity on this construction would be almost as much violated as if the consideration had been purely voluntary. Had the sum received by the grantor been a cent merely, it would be serious trifling to contend that the nature and effect of the provision was changed by it. Between this sum and five dollars, the four hundredth part in value of the property conveyed, there is no material difference.”

In the case of Meeker v. Meeker, 16 Conn. 383, it was held:

“Where the consideration expressed in a deed made from a father to his son was two thousand dollars, * * * parol evidence was •admissible to show, that nothing was in fact paid, but that the conveyance was made as an advancement to the son.” Devlin, Deeds Sec. 829.

On the other hand, it is stated in Devlin, Deeds See. 810:

“The recital in the deed that pecuniary consideration' has been paid so far as the legal effect of the conveyance as a deed of bargain and sale is concerned, is conclusive. By this is meant simply the effect of the deed aside from any question of fraud.”

The text in this section is also supported by many decisions and one that is curious would be interested in noticing the directly opposed decisions in the different states.

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Related

Hatch v. Straight
3 Conn. 31 (Supreme Court of Connecticut, 1819)
Meeker v. Meeker
16 Conn. 383 (Supreme Court of Connecticut, 1844)
Steele v. Worthington
2 Ohio 182 (Ohio Supreme Court, 1825)

Cite This Page — Counsel Stack

Bluebook (online)
18 Ohio C.C. Dec. 71, 7 Ohio C.C. (n.s.) 277, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cowden-v-cowden-ohcirctmahoning-1905.