Estep v. Estep

30 Va. Cir. 447, 1951 Va. Cir. LEXIS 2
CourtShenandoah County Circuit Court
DecidedNovember 9, 1951
StatusPublished

This text of 30 Va. Cir. 447 (Estep v. Estep) is published on Counsel Stack Legal Research, covering Shenandoah County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estep v. Estep, 30 Va. Cir. 447, 1951 Va. Cir. LEXIS 2 (Va. Super. Ct. 1951).

Opinion

BY JUDGE ELLIOTT MARSHALL

In this case the demurrer challenges the sufficiency of the averments of the bill of complaint on the ground that the will sought to be construed is so plain and unambiguous that no judicial construction thereof is necessary and on the further ground that the construction urged by the complainants would be contrary to the law. While I have doubts as to whether the court could sustain the demurrer on the grounds assigned because a construction of the will would be necessary in order to decide the issues raised, counsel tacitly consented to a judicial construction of the will at this stage of the case.

The testator in this case has presented us with a peculiar and difficult problem. In the fourth clause of the will the residue of his estate, both real and personal, after the payment of all debts, is devised in general terms to his sister. In the fifth clause he provides that “in case” his sister should die or marry “what I have willed to her” shall be divided among his nieces and nephews.

The complainants contend that the estate created in the sister, the first taker, was either a life estate subject to be divested on marriage of [448]*448the first taker or a fee subject to be defeated upon the condition subsequent of marriage.

The defendants first contend that the sister is vested absolutely and in fee simple because the fourth clause, the devise and bequest being in general terms and without limitation, created a fee simple and any attempt thereafter in the fifth clause to limit the fee would be void because of repugnancy. They urge that the doctrine of May v. Joynes, 61 Va. (20 Gratt.) 692 (1871), and the long line of authorities following if and repeating its fundamental principles, irrespective of the changes in the Virginia Statute (Virginia Code, § 55-7) control us in the construction of the instant will. Their argument is that once we perceive the intention of the testator to create a fee simple, then this intention is controlling and we must view all other language in the will as subsidiary desires of the testator and an illegal attempt to limit the full estate previously created. This is no doubt true once it be conceded that the plain intent of the testator was to create a fee simple in the first taker. If such an intent is not made clear under the provisions of the will the rule of May v. Joynes would not apply.

One of the most certain methods of ascertaining the testator’s intention as to the quantum of the estate created is to examine his provisions as to the rights which he intends the devisees to exercise over the property; this is true even though the technical language used in the creation of the estate might indicate to the contrary. If the devisee is granted rights in the property which are inconsistent with life tenancy but consistent with fee simple ownership, the courts perceive that it was the intention of the testator to create a fee simple rather than a life estate; and, of course, the converse is true. Thus, in May v. Joynes, supra, while the testator created in the first taker an express life estate, his provision that she should have absolute power of disposition, being one of the most important incidents of ownership in fee simple and being inconsistent with life tenure, the dominant intention of the testator was found to be the creation of a fee simple and the will was so construed. It is, of course, not necessary that the power of disposition be express. It can be created by implication from the language of the will. Skinner v. Skinner, 158 Va. 326 (1932); Whitehead v. Whitehead, 174 Va. 379 (1940).

In the instant case the will contains no express provision for power of disposition in the first taker and there are no other expressions of the testator as to any rights to be exercised by her over the property. The [449]*449language of the will as a whole must, therefore, be scrutinized to ascertain whether the power of disposition or other rights incident to fee simple tenure be created by implication.

The only case cited which may be of value in deciding as to the creation of the power by implication is Whitehead v. Whitehead, supra. Of course, in that case the testator in creating the estate in the first taker used the technical phrase “in fee simple." But because of the later provision as to the attempted disposition of the property upon the death or remarriage of the first taker, the court examined the will to ascertain the true intention of the testator as to the quantum of the estate, thus tacitly admitting that the use of the technical phrase creating a fee simple estate was not controlling if the whole language of the will indicated to the contrary. (This proposition is unanimously sustained by the authorities). The court, upon examining the will, found an implied power of disposition in the first taker because of the use of the phrase “balance of my estate" in attempting to create a vested remainder upon the death of the first taker or a remainder contingent upon remarriage of the first taker, (or, possibly, a condition to defeat a fee in the first taker). It was the opinion of the court that the use of the words “balance of my estate" indicated that the testator contemplated that his estate might not be intact at the death or remarriage of the first taker; therefore, he intended that she should have power of disposition. Although the court did not say so the language was construed to intend the same as the will concerned in Skinner v. Skinner, supra, which provided for a reversion upon the death of the first taker of “such remaining part of the bequest as she shall die possessed of." Of course, the implication of the language of the latter case is much clearer than the former. In the Whitehead case, Holt, J., in his dissent disagreed with the construction that the majority placed on the phrase “balance of my estate." He thought that this phrase was simply a reiteration of the same language used to describe the property devised to the first taker and could not be construed to grant the power of disposition by implication.

Reading the instant will it is difficult to perceive how the language of the will could be construed to create in the first taker a power of disposition or any rights incident to ownership in fee simple. The defendants attempt to draw an analogy between this and the Whitehead case because of the use of the phrase “remainder of my possessions" in the fourth clause. The answer to this is that the significance of the [450]*450phrase “balance of my estate” in the Whitehead case was that it was used in describing the property to go to the second taker. This is not the situation hero. I can find nothing in the instant will to imply the actual intention of the testator that the first taker should have power of disposition. There is nothing to indicate that the testator anticipated that the estate devised to the first taker would not be intact at her death.

The defendants next contend that the phrase “what I have willed to her" (the first taker) indicates the intention of the testator that she should exercise full rights of ownership over the property. I cannot agree with this contention. I think that this phrase could be just as logically construed to indicate that the testator contemplated that the estate would remain intact in the hands of the first taker until her death or marriage, and, therefore, that she should have no power of disposition.

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Related

Barksdale v. White
26 Am. Rep. 344 (Supreme Court of Virginia, 1877)
Smythe v. Smythe
19 S.E. 175 (Supreme Court of Virginia, 1894)
Meek v. Fox
88 S.E. 161 (Supreme Court of Virginia, 1916)
Skinner v. Skinner's Administrator
163 S.E. 90 (Supreme Court of Virginia, 1932)
Whitehead v. Whitehead
6 S.E.2d 624 (Supreme Court of Virginia, 1940)
Moore v. Holbrook
9 S.E.2d 447 (Supreme Court of Virginia, 1940)

Cite This Page — Counsel Stack

Bluebook (online)
30 Va. Cir. 447, 1951 Va. Cir. LEXIS 2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estep-v-estep-vaccshenandoah-1951.