Dengler Estate

13 Pa. D. & C.2d 193, 1958 Pa. Dist. & Cnty. Dec. LEXIS 348
CourtPennsylvania Orphans' Court, Philadelphia County
DecidedMarch 28, 1958
Docketno. 245 of 1957
StatusPublished
Cited by1 cases

This text of 13 Pa. D. & C.2d 193 (Dengler 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
Dengler Estate, 13 Pa. D. & C.2d 193, 1958 Pa. Dist. & Cnty. Dec. LEXIS 348 (Pa. Super. Ct. 1958).

Opinion

Lefever, J.,

This is an appeal from the action of the register in probating and granting letters upon an alleged will, dated May 18, 1955. The learned hearing judge heard the testimony of the subscribing witnesses, the testimony of the contestants’ witnesses and only a portion of the evidence offered by the proponents. At the conclusion of the testimony of one of the proponents’ witnesses, who was also a subscribing witness, the hearing judge interrupted the hearing and ordered a jury trial on the issues of undue influence, and the mental and physical capacity of testatrix to make the disputed will. Proponents filed exceptions to this order. The case is before us on those exceptions.

This case raises for the first time the question of the right and power, invested by the recent amendments to the Orphans’ Court Act of August 10, 1951, P. L. 1163, in the hearing judge, to order a jury trial prior to the completion of the hearing of a will contest, and the further question as to whether such an order is reviewable by the court en banc prior to the jury trial.

The orphans’ court judge assigned to hear a will contest now has authority to summon a jury at any [195]*195stage of the proceedings. This authority stems from the Act of February 10, 1956, P. L. 1022, which amends the Orphans’ Court Act of 1951. The amended sections, with the comments of the Joint State Government Commission1 are as follows:

“Section 744. Testimony in Proceedings Removed from Register. — On appeal from the register, or in a proceeding removed from the register, the court may find, upon the testimony taken before the register, that a substantial dispute of facts exists and grant a jury trial. When upon the testimony taken before the register a jury trial is not granted, the court shall hear the testimony de novo unless all parties appearing in the proceeding agree that the case be heard on the testimony taken before the register. In any event, the court may require witnesses already examined and other witnesses to appear before it. The court, in its discretion, may impanel a jury at any stage of the proceedings.
“Comment — 1956 Amendment — The addition of the last sentence to this section, together with Section 746 (a. 1), is intended to make it possible for the orphans’ [196]*196court to award a jury trial or impanel a jury at any stage of the proceedings before or after any or all of the testimony is heard, thus avoiding any duplication of hearings.
“Section 746. Trials in the Orphans’ Court.— (a) Jury . . .
“(a.l). In any case begun before or certified or appealed to the orphans’ court, the court may, on its own motion or on motion of a party and with reasonable notice to all parties, (1) combine the hearing to determine whether a substantial dispute of fact exists with the trial to determine the dispute, and impanel a jury before determining whether or not a substantial dispute of fact exists, and (2) combine the hearing and trial on all wills, the issues in regard to which are closely interrelated. The court may withdraw the case from the jury, if the court determines no substantial dispute of fact exists.
“Comment — 1956—Act—The addition of this subsection makes it possible for the court to determine whether or not a substantial issue of fact exists and to dispose of the case on its merits in one proceeding, thus avoiding the burden of two trials when one will suffice.” (Italics supplied.)

The language and intention of the statute, as amended, is clear. It empowers the hearing judge, in his discretion, to impanel a jury (1) upon the record before the register; (2) upon the allegations in the pleadings; (3) upon the facts revealed at a pretrial conference; or (4) at any point during the hearing, when the evidence warrants. In short, the hearing judge is empowered (1) to begin the hearing with a jury, or (2) to interrupt the hearing at any point, summon a jury and proceed de novo before the jury.

Administrative problems may arise in connection with the hearing judge’s exercise of this discretion. [197]*197Juries are not always available on dates fixed by the orphans’ court for will contests. Other court engagements may preclude the hearing judge, who has devoted hours or days to the hearing of a will contest, from proceeding immediately with the jury trial. Moreover, either he or the court may deem it advisable to assign the jury trial to another judge of the court. Therefore, it may be necessary or advisable to schedule the jury trial for a later date. However, this does not curtail the absolute power and discretion, invested by the act in the hearing judge, to order a jury trial.

There is no doubt that an order by the hearing judge, refusing to award a jury trial and dismissing the appeal, is a final order which is subject to review by the court en banc and thereafter by the appellate courts. The reason for this is apparent. The order of the hearing judge, unless reversed, terminates the litigation.

In contrast, the order of the hearing judge awarding a jury trial does not decide or conclude the issue. Therefore, it is interlocutory. Accordingly, such an order is not subject to appeal to the appellate courts: Schwilke’s Appeal, 100 Pa. 628; Judge Hunter’s Pennsylvania Orphans’ Court Commonplace Book, volume I, page 206. See also Shepard’s Estate, 170 Pa. 323, 326. In Schwilke’s Appeal, supra, the court said, at page 631:

“If the court refuse to award the issue, it is such a definitive decree that an appeal therefrom lies to this court. In that case we consider the whole evidence on which the court below decided, and determine as to the correctness of its conclusion.
“Directing the issue is not a definitive decree from which an appeal lies to this court. It is preliminary only. It is merely one step toward obtaining the verdict of a jury. . . .”

It logically follows that the award of an issue by a hearing judge is not reviewable by the court en banc. [198]*198There is little law on this subject. On occasion, possibly as a matter of grace, exceptions to the award of an issue have been heard.2 However, the amended act, empowering the hearing judge to impanel a jury at any point in the proceedings, eliminates any possible doubt that such an order is interlocutory and not subject to review by the court en banc. Were this not so, the discretion would be vested in the court en banc rather than in the hearing judge. Moreover, to grant immediate review would defeat the legislative intent of the amendments, namely, to eliminate, or, at least, to reduce duplication of trials in will contests.

It was argued that our local rule 77.1 (a)3 impliedly authorizes the filing of the present exceptions to the order of the learned hearing judge in this case. Where there is a conflict between our rules and a later statute, the latter governs.4 Accordingly, we hereby rule that there is no right under our local rules to file exceptions to the award of a jury trial in a will contest.

We decide, therefore, that the order of the learned hearing judge in awarding a jury trial in the instant case is not now reviewable by the court en banc. Accordingly, the present exceptions are premature and must be dismissed.

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171 A.2d 171 (Supreme Court of Pennsylvania, 1961)

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Bluebook (online)
13 Pa. D. & C.2d 193, 1958 Pa. Dist. & Cnty. Dec. LEXIS 348, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dengler-estate-paorphctphilad-1958.