Esack Estate

1 Pa. D. & C.2d 216, 1954 Pa. Dist. & Cnty. Dec. LEXIS 184
CourtPennsylvania Orphans' Court, Philadelphia County
DecidedNovember 19, 1954
StatusPublished

This text of 1 Pa. D. & C.2d 216 (Esack 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
Esack Estate, 1 Pa. D. & C.2d 216, 1954 Pa. Dist. & Cnty. Dec. LEXIS 184 (Pa. Super. Ct. 1954).

Opinion

Shoyer, J.,

Can a widow claim her $750 exemption out of partnership assets in the hands of an assignee for the benefit of partnership creditors ahead of the creditors of the partnership? This question is raised by the joint petition of the administrator c. t. a. of the estate of decedent and the latter’s widow, and the responsive answer filed by the assignee for benefit of the partnership creditors.

David Esack died June 30, 1954, and in the pleadings it was admitted that both decedent and the partnership were insolvent at the time of his death. On July 12,1954, the administrator c. t. a. and the surviving partner jointly executed an assignment of partner[217]*217ship assets for the benefit of creditors of the partnership to one George J. Cherry. At the argument before the court en banc it was admitted by counsel for petitioners that the creditors of the. partnership would probably receive but 55 or 60 cents on the dollar, leaving nothing for the claims of individual creditors of decedent.

The widow’s claim (now called family exemption) arises under section 211 of the Fiduciaries Act of April 18, 1949, P. L. 512, 20 PS §320.211, reading as follows:

“The spouse of any decedent . . . may retain or claim as an exemption and as a reasonable requirement for support during the settlement of the estate, either real or personal property, or both, not theretofore sold by the personal representative, to the value of $750.00.”

Reference to the comment following this section, made by the Joint State Government Commission of the Pennsylvania Legislature, discloses that this section is based on section 12(a) of the Fiduciaries Act of June 7, 1917, P. L. 447; which in turn was founded upon the Act of April 14,1851, P. L. 612: Bell’s Estate, 139 Pa. Superior Ct. 11 (1939).

Traditionally, the widow’s claim for exemption has received most favorable treatment at the hands of the courts. The underlying and guiding principles have been declared in a host of cases: Stokes Estate, 167 Pa. Superior Ct. 128, 131 (1950). The Fiduciaries Act of 1949 is a revision and consolidation of the prior law, and there is nothing in section 211, et seq.,.to indicate that the legislature intended, to radically change the existing law on the subject. . “The authorities construing these former statutes, therefore, are persuasive in the interpretation of the section-under consideration:” Bell’s Estate, supra, at p. 12. In Miles’ Estate, 272 Pa. 329, 339 (1922), it was held that “when the statute under consideration is a general [218]*218revision, ‘the law as therein written will be deemed to be the same as it stood prior to the revision, unless we find from the statute itself, or its history, a clear intention to change it’: In re Lis’s Est., 139 N. W. 300, 302, and cases there cited; see also authorities in 36 Cyc. 1223.”

As to the nature and interpretation of the earlier statutes it has been said:

“The exemption provision in the Act of 1917 is not a statute of distribution, and the exemption is not an inheritance. It is wholly a gratuity, based upon the existence of the family relationship at the time of decedent’s death: Hildebrand Estate, 262 Pa. 112, 104 A. 866; Est. of John B. Fenyo, 105 Pa. Superior Ct. 560, 161 A. 606. . . The statutory exemption is a preferred claim or gift of the law prompted by consideration of public policy; Peebles’ Estate, 157 Pa. 605, 27 A. 792, and exemption statutes have always received an interpretation consistent with their conception; Hildebrand’s Estate, supra. These statutes have always been considered rather according to their spirit than to the letter: Nevin’s Appeal, 47 Pa. 230. The purpose of that Act [April 14, 1851, P. L. 612] was to-make immediate provision for the wants of the family when the head of it is removed by death. . . . This is obvious from the language and history of the law. . . The motive of the enactment is clearly traceable, in the legislation of the State, to the family necessity:’ Hettrick v. Hettrick, 55 Pa. 290;” Bell’s Estate, supra, at pp. 13, 14 and 15.

“The exemption has been variously described: a gratuity, Cramm’s Estate, 127 Pa. Superior Ct. 446, 193 A. 135, affirmed 329 Pa. 528, 198 A. 653; ‘a preferred claim or gift of the law, prompted by considerations of public policy’, Peebles’ Est., 157 Pa. 605, 609, 27 A. 792; an independent bounty whereby the exempted property is withdrawn from the estate and the [219]*219general course of administration. Compiler v. Compiler, 25 Pa. 31. It is not an estate which passes to the widow by will or under the intestate laws. It is an inchoate right of the widow in her husband’s estate which becomes complete only when the exemption is claimed and allowed. Hildebrand’s Est., 262 Pa. 112, 104 A. 866; Murray Est., 158 Pa. Superior Ct. 504, 45 A. 2d 411.”: Stokes Estate, supra, at p. 131.

A liberal, rather than a strict literal construction, is to be applied to this latest codification: Gravatt’s Estate, 50 D. & C. 679, 681, 682 (1944); especially in view of the fact that the legislature itself has broadened the exemption by extending its privileges to widowers and by increasing the amount from $500 to $750.

Purchase money mortgages still retain their priority as under the earlier statutes (section 216), but case law protecting all mortgagees is not. changed by the Act of 1949, and the legislature is apparently satisfied .that the reasoning of our Supreme Court in Kauffman’s Appeal, 112 Pa. 645 (1886), fully justifies the protection there extended to all such lienholders.

It is significant, however, that payment of the widow’s exemption has always been made out of assets belonging to decedent or in the hands of his personal representative. We know of no case where the widow’s claim has been addressed to the assignees for the benefit of partnership creditors, and cpunsel for petitioners has cited no such authority to us. Just as the widow’s rights are based on statute, so are the duties and responsibilities of respondent assignee. These are set forth in section 40 of the Uniform Partnership Act of March 26, 1915, P. L. 18, 59 PS §102, as follows: The assignee is required to distribute the assets of the partnership in payment of “the liabilities of the partnership” to creditors in the following order:

[220]*220“(b) I. Those owing to creditors other than partners,

“II. Those owing to partners other than for capital and profits, • ■

“III. Those owing to. partners in respect to capital,

“IV. Those owing to partners in respect of profits. ...

“, (h) When.partnership property and the.individual properties of the partners are in the possession of a court for distribution, partnership creditors shall have priority on . partnership property, and separate .creditors on individual property, saving the rights of lien or secured creditors as heretofore.

“(i) Where a partner has become bankrupt or his estate is insolvent the. claims against his separate property shall rank in the following order:

“I. Those owing to separate creditors,

“II. Those owing to partnership creditors,

“III. Those owing to partners by way of contribution.”

Long before the adoption by the Pennsylvania Legislature of the Uniform Partnership Act, ease law had established the distribution of assets in the same order as set forth in subsection (h), supra. Thus in Black’s Appeal, 44 Pa.

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Related

Froess v. Froess
131 A. 276 (Supreme Court of Pennsylvania, 1925)
Cramm's Estate
198 A. 653 (Supreme Court of Pennsylvania, 1938)
In Re Estate of John Balog Fenyo
161 A. 606 (Superior Court of Pennsylvania, 1932)
Murray Estate
45 A.2d 411 (Superior Court of Pennsylvania, 1945)
Cramm's Estate
193 A. 135 (Superior Court of Pennsylvania, 1937)
Bell's Estate
10 A.2d 835 (Superior Court of Pennsylvania, 1939)
Compher v. Compher
25 Pa. 31 (Supreme Court of Pennsylvania, 1855)
Black's Appeal
44 Pa. 503 (Supreme Court of Pennsylvania, 1863)
Nevins's Appeal
47 Pa. 230 (Supreme Court of Pennsylvania, 1864)
Hettrick v. Hettrick
55 Pa. 290 (Supreme Court of Pennsylvania, 1867)
Kauffman's Appeal
4 A. 20 (Supreme Court of Pennsylvania, 1886)
Peebles's Estate
27 A. 792 (Supreme Court of Pennsylvania, 1893)
Hildebrand's Estate
104 A. 866 (Supreme Court of Pennsylvania, 1918)
Miles's Estate
116 A. 300 (Supreme Court of Pennsylvania, 1922)
Stokes Estate
74 A.2d 517 (Superior Court of Pennsylvania, 1950)
Austro-Hungarian Consul v. G. A. Westphal
139 N.W. 300 (Supreme Court of Minnesota, 1912)

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Bluebook (online)
1 Pa. D. & C.2d 216, 1954 Pa. Dist. & Cnty. Dec. LEXIS 184, Counsel Stack Legal Research, https://law.counselstack.com/opinion/esack-estate-paorphctphilad-1954.