Dull Estate

33 Pa. D. & C.2d 157, 1964 Pa. Dist. & Cnty. Dec. LEXIS 282
CourtPennsylvania Orphans' Court, Dauphin County
DecidedJanuary 29, 1964
Docketno. 3 of 1940
StatusPublished

This text of 33 Pa. D. & C.2d 157 (Dull Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Dauphin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dull Estate, 33 Pa. D. & C.2d 157, 1964 Pa. Dist. & Cnty. Dec. LEXIS 282 (Pa. Super. Ct. 1964).

Opinion

Swope, P. J.,

This case is before the court on questions raised to the suggested schedule of distribution of the remainder of the Wilma G. Knodell residuary trust as proposed by the National Bank & Trust Company of Central Pennsylvania, substituted trustee under the will of Judith R. Dull, deceased, in its first and final account.

Judith R. Dull died on January 7, 1920, a resident of Dauphin County, Pennsylvania. The aforementioned trust was created in paragraphs VIII and XIX of her last will and testament and paragraph 3 of the codicil thereto, as the same were admitted to probate on January 13,, 1920, in this county, and duly recorded.

Inter alia, the trust provided for a life estate in Wilma G. Knodell, she also being given a power of appointment over the remainder.

On February 8, 1961, Wilma G. Knodell died a resident of Summit County, Ohio. At that time, it was believed that she had died intestate. A will was discovered subsequently, however, which was probated on February 9,1962, in Summit County, Ohio. It had been executed in April, 1921, prior to the date of Wilma G. Knodell’s marriage to Eugene Knodell on October 14, 1922, and contained among its provisions, the following:

FIRST: I direct that all my just debts and funeral [159]*159expenses be fully paid and satisfied, as soon as conveniently may be, after my decease.
FIFTH: I give and devise and bequeath to my sister, Elizabeth R. Castle, all of the remainder of my estate, including such estate, interest and income as was vested in me by and under the will of my Great Aunt, Judith R. Dull. I hereby appoint my sister, Elizabeth R. Castle as the beneficiary provided for in the said last will and testament of Judith R. Dull.

Elizabeth R. Castle prédeceased her sister, Wilma G. Knodell, leaving to survive as her only child, a son, Gates R. Castle.

On February 9, 1962, Eugene E. Knodell, surviving spouse of Wilma G. Knodell, filed in Probate Court of Summit County, Ohio, an election to take against her will.

We have been asked to determine whether Wilma G. Knodell, in exercising the power of appointment, effected a blending of the appointive estate with her own personal estate for any purpose whatsoever. This issue is properly for determination by this court, under applicable Pennsylvania law, rather than by an Ohio Court, under the law of that jurisdiction.

In Barton Trust, 848 Pa. 279, 35 A. 2d 266 (1944), the basic conflicts of law principle underlying this question was broadly stated by the Pennsylvania Supreme Court in the following language, at pages 281-282:

“In order to determine whether the residuary clause constituted an exercise of the power it is first necessary to decide by the law of what state that question is governed. In executing a power of appointment the donee disposes of the estate as that of the donor, the appointment being referred back to the instrument which created the power as if it had been actually embodied therein, and it is no doubt because of this principle that it has been uniformly held that the proper and effective [160]*160exercise of a power of appointment is, in the case of personalty, controlled by the law of the donor’s domicile at the time of the creation of the trust: [Citing cases] See also O’Reilly Estate, 371 Pa. 349 (1952).

With regard to the correlative determination of whether or not a blending was effected by the exercise of the power of appointment, we note that when the Orphans’ Court of Philadelphia County was faced with the question as to whether or not an out-of-State resident, in exercising a power of appointment over a Philadelphia domiciled trust, had blended the trust corpus with his personal estate, Judge Hunter assumed jurisdiction without extensive elaboration as to the source of his authority and applied Pennsylvania law to determine the issue on its merits: Beddall Trust, 1 Fiduc. Rep. 149 (1947). Consistently, the Orphans’ Court Act of August 10, 1951, P. L. 1163, sec. 306, provides that venue in the case of a testamentary trust, lies in the county wherein jurisdiction was first assumed.

It appears presently, therefore, that where a Pennsylvania resident establishes a testamentary trust, with a Pennsylvania trustee, providing for a life interest with a power of appointment in the beneficiary, and that beneficiary moves to another State wherein the power of appointment is exercised in such a way that the question of blending is raised, this question will be resolved by the orphans’ court of that county wherein jurisdiction was first maintained, in accordance with Pennsylvania law.

The case at bar presents exactly these circumstances. We have a Dauphin County settlor and a Dauphin County trustee. The only out-of-State act consisted of the exercise of the power of appointment in another jurisdiction, which fact will not be taken as sufficient to preclude this court from assuming jurisdiction over any question involving the effective accomplishment [161]*161thereof, even to the extent of determining whether or not a blending has taken place: Beddall Trust, supra.

Accordingly, we conclude that the language contained in the residuary clause of Wilma G. Knodell’s will is not of the type which may be construed as effecting a blending of her personal and appointive estates, either generally or for the purpose of distribution only.

In Shipley’s Estate (No. 2), 337 Pa. 580, 12 A. 2d 347 (1940), the testatrix was the holder of a power of appointment. In her will, she provided, inter alia, for payment of her debts out of her “general estate”. In her residuary clause she provided that: “All the rest, residue and remainder of my property and estate, real, personal and mixed, of whatsoever kind and description and wheresoever situate, including all property and estate over which I may have any testamentary power of appointment, I direct shall be divided by my Executor into three equal parts or shares and I give, devise and bequeath said equal parts or shares, as follows. . . .”

The court found that there was no blending of testatrix’ personal and appointive estates either by the term “general estate” or in the residuary clause. Significantly, the court looked to the canon of construction of wills which provides that the probable intention of decedent most agreeable to reason and justice should prevail, citing Jackson’s Estate, 337 Pa. 561, then holding, at page 586:

“It seems ‘agreeable to reason and justice’ that the testatrix would provide for her collateral relatives, friends and charities out of her individual estate, and that she would direct that such portion of her father’s estate over which she had the power of appointment should go to the descendants of her father exactly as he himself as a testator had directed in distributing that portion of his estate which he completely disposed of.”

In Anderson Estate, 373 Pa. 294 (1953), the court [162]*162was again asked to determine whether a blending had been effected in the will of one holding a power of appointment. The first paragraph of the will provided that decedent’s just debts be paid, and thereafter, in his residuary clause he provided:

“. . . divide all the rest, residue and remainder of my Estate . . . including such property over which I shall be given the power of appointment under the . . . Last Will... of my wife . . .

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Related

O'Reilly Estate
89 A.2d 513 (Supreme Court of Pennsylvania, 1952)
Anderson Estate
95 A.2d 674 (Supreme Court of Pennsylvania, 1953)
Barton Trust
35 A.2d 266 (Supreme Court of Pennsylvania, 1943)
Kates's Estate
128 A. 97 (Supreme Court of Pennsylvania, 1925)
Jackson's Estate
12 A.2d 338 (Supreme Court of Pennsylvania, 1940)
Shipley's Estate (No. 2)
12 A.2d 347 (Supreme Court of Pennsylvania, 1940)

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Bluebook (online)
33 Pa. D. & C.2d 157, 1964 Pa. Dist. & Cnty. Dec. LEXIS 282, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dull-estate-paorphctdauphi-1964.