Crockett v. Davis

1 Balt. C. Rep. 502
CourtBaltimore City Superior Court
DecidedDecember 22, 1892
StatusPublished

This text of 1 Balt. C. Rep. 502 (Crockett v. Davis) is published on Counsel Stack Legal Research, covering Baltimore City Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crockett v. Davis, 1 Balt. C. Rep. 502 (Md. Super. Ct. 1892).

Opinion

RITCHIE, J.

Catharine Davis, being then a widow, executed her will on the 13th day of August, 1890. She, at that time, had living four children by her first marriage and three children by her second marriage. A caveat has been filed to the will by the children of the first marriage; Mrs. Davis having left nearly all of her estate to the children by her second marriage.

Four issues have been sent to this Court to be passed upon; they involve the due execution of the will, the knowledge upon the part of the testatrix of its contents, the exercise of undue influence, and testamentary capacity. Its due execution has been proved, and there is no controversy over the factum of the will; that being so, the testatrix is presumed to have had knowledge of its contents, provided she had mental capacity sufficient to make a will. The caveatees, before offering any testimony, have asked the Court to instruct the jury that, on the case made out by the plaintiffs, there is no evidence legally sufficient, upon the remaining two issues of duress and testamentary capacity, to go to the jury, and I am obliged to grant this instruction. In doing so, it is due to the able argument made by Mr. Field upon behalf of the caveators, that I should give a little more fully than I otherwise would, the reasons for my ruling.

The rule as to the legal sufficiency of testimony has been repeatedly stated by the Court of Appeals. As concisely laid down in Tyson’s case, it is that the Court ought not to allow a case to go to the jury unless the evidence is of such a character as would warrant the jury, in the exercise of a reasonable intelligence, in finding the fact alleged. As applied to this case, there must be evidence which would warrant the jury, in the exercise of a reasonable intelligence, in finding either the exercise of undue influence, or the want of testamentary capacity. Or, adapting the language used in Foy’s case, there must be evidence upon which the jury might reasonably and properly conclude that there was the exercise of undue influence, or that there was the want of mental capacity. If there is no such evidence, it is the duty of the Court to so rule. This is the law that is given to me, and I must follow it according to the best of my judgment.

First, as to the issue of undue influence. This lady was sixty-five years of age at the time she executed her will; the evidence shows that during all her life she had been a woman of more than usual power of will and firmness of character. There is no suggestion, at least no suggestion of any importance, that she became deficient in this respect, until after the death of her husband, which occurred in April, 1890. four months before the execution of her will. It is in testimony that at that time she began to show the effects of a life of much hard work, that her health had somewhat failed, and, in general terms, it is testified to that during the period between the death of her husband and the date of the execution of her will, she was easily influenced, was easily persuaded. These are the expressions used by the witnesses who testify on this point, that she could be easily persuaded that she could be during the period in question, easily influenced. But there is no evidence whatever in the case to show that any one ever did exercise any influence over her, that any one ever attempted to exercise any influence over her, or that [503]*503she was, in fact, ever subject to the influence of anybody; there is no instance given by a single witness, which under the rule governing the sufficiency of evidence, would tend to show that she was ever subject to any undue influence from any quarter.

Of course, in connection with other testimony on the issue of undue influence, the provisions of the will may be considered, and I will refer to them a little later. It has also been argued by the caveators that there is such gross inequality in the dispositions of the will as to change the onus, and make it incumbent on the beneficiaries to show affirmatively that the testatrix was free from undue influence. This practically invokes by analogy the doctrine of confidential relations as applied in equity to gifts inter vivos. I do not think the facts of this case bring it within any of the authorities cited on this point, but even if they did, I do not think those cases, in view of what is held by the Court of Appeals in Tyson’s case and Griffith’s ease, would be accepted as authority in this State.

Now as to testamentary capacity. In order to be competent to make a will, a testator must be of sound and disposing mind, and capable of making a valid deed or contract. When we come to the consideration of this issue, the field that may be covered is a very broad one; almost anything connected with the testator may be properly taken into consideration; age, health, estate, family, the condition and necessities of the different members of his family, the relations existing between him and them, the claims that any may have upon his bounty, and all the surroundings of the testator may be considered, so far as they throw any light upon the question of mental capacity.

We find that the first husband of Mrs. Davis, Mr. Jenkins, died in 1861; the children by her first marriage are the caveators; in 1862 she married Mr. Davis, who died in April, 1890; the three children by the second marriage are the beneficiaries under her will: she made this will on August 13, 1890, and died in February, 1892. She is showm to have been a capable business woman; she was active, industrious, and intelligent: and the testimony upon all sides is that she was a clear-headed and more than usually competent business woman, at least down to the very latest years of her life. Such was her mental character during all the active period of her life.

It is claimed first, that there is evidence of want of mental capacity in the provisions of her will, that its provisions are unnatural and unjust. It is hardly necessary to say that if a testator is of sound mind and free from undue influence, he is at liberty to make any disposition of his property that he sees proper, consistent with the policy of the law, and Courts have no right, they have no power to control the disposition that any testator — who is free and competent — may see proper to make of his property. His right to dispose of his property by will is just as ample as his right to dispose of it by deed during his life. We have no right to make wills for people, or to set aside those made simply because to us they may seem unjust or injudicious. The provisions of the will, however, read in the light, of surrounding circumstances, and in connection with them, may of course be considered in passing on the question of capacity. But we should act very cautiously in forming an opinion of mental unsoundness because of the provisions of any will. It is important to remember that the testator is not here to explain his motives. The effort in an inquiry of this kind is to place the testator before the jury just as ho was when he made his will; to show not only his actual situation and surroundings, but also, as far as possible, his thoughts and feelings and all considerations which may have influenced his action. But with all our effort this can be only imperfectly done. The law does not require him to assign his motives for the will he makes. Very few men discuss their proposed wills with others unless in the utmost confidence, and the law recognizes the fact that a testator may often have sufficient reasons for discrimination, or for unexpected dispositions, which he would be reluctant to disclose. Cramer vs. Orumbaugh, 3 Md. 499.

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Related

Cramer v. Crumbaugh
3 Md. 491 (Court of Appeals of Maryland, 1853)

Cite This Page — Counsel Stack

Bluebook (online)
1 Balt. C. Rep. 502, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crockett-v-davis-mdsuperctbalt-1892.