Fagan v. Welsh

32 Ohio C.C. Dec. 409, 19 Ohio C.C. (n.s.) 177, 1909 Ohio Misc. LEXIS 439
CourtCuyahoga Circuit Court
DecidedJanuary 25, 1909
StatusPublished

This text of 32 Ohio C.C. Dec. 409 (Fagan v. Welsh) is published on Counsel Stack Legal Research, covering Cuyahoga Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fagan v. Welsh, 32 Ohio C.C. Dec. 409, 19 Ohio C.C. (n.s.) 177, 1909 Ohio Misc. LEXIS 439 (Ohio Super. Ct. 1909).

Opinion

METCALFE, J.

This action was brought by Kate Fagan, plaintiff herein, in the court below, to contest the will of Coena Murphy.

The errors complained of all relate to requests for instructions to the jury, and the general charge of the court. The question of the weight of the evidence is not raised, and the whole evidence does not appear in the record. There was a verdict and judgment in the lower court sustaining the will and this action is to reverse that judgment.

[410]*410The facts, so far as they are necessary to an understanding of the questions raised, are as follows :

Coena Murphy was an orphan girl of about the age of 20 years at the time of the execution of this will. She was possessed of some property, consisting mostly of real estate in the city of Cleveland. Some time in 1905, Vm. T. Clark was by the probate court of this county appointed guardian of her person and property, under favor of Sec. 6317 R. S. (Sec. 11011 G. C.), on the ground that she was incapable of taking proper care of herself or her property by reason of intemperance. It appears also that before this appointment an application was made for the appointment of a guardian on the ground of mental incapacity, which failed or was withdrawn, as appears. In accordance with some understanding between the parties, Mr. Clark, upon his appointment as guardian, made an arrangement with the defendant, Bridget Welsh, to board and care for his ward, and from that time until her death, which occurred in June, 1905, Coena Murphy continued to reside with Mrs. Welsh. The will in question was made by someone in Mr. Clark’s office, a few weeks before Coena’s death, and gave all her property to' Mrs. Welsh. At the time Mr. Clark made his arrangements with Mrs. Welsh to take care of Coena, he gave her some general directions about the way she was to be taken care of.

There is no evidence in the record tending to show undue influence or mental incapacity, and the only questions raised in the case come from the refusal of the court to give certain requests to charge, made by plaintiff in error; the giving of certain requests made by the defendants, and alleged error in the general charge.

The fifth and sixth requests to charge before argument, raise this question: Did Mrs. Welsh stand in the same relation to Coena Murphy as her guardian to such an extent that the mere fact that Coena made her will in Mrs. Welsh’s favor raised a presumption that the will was procured by undue influence. And, if so, was the burden of the proof thereby thrown upon the proponents of the will to disprove undue influence on the part of Mrs. Welsh?

We are unable to see how the mere fact that Mrs. Welsh [411]*411was employed and paid by Coena’s guardian to board and care for her could place her. in the same fiduciary capacity as the guardian himself. It is true that Mrs. Welsh took Coena into her house, probably treated her as a member of her family; perhaps was a mother to her. This family relation would undoubtedly be one of trust and confidence between Mrs. Welsh and Coena, which if there were any evidence tending in any way to show had been used by Mrs. Welsh to induce the making of the will, would undoubtedly raise a suspicion of unfairness and perhaps a presumption which it would be necessary to rebut.

This would be more particularly so if there were evidence tending to show mental weakness on the part of Coena. We do not think, however, that we are required to entertain a presumption of mental weakness on account of the guardianship alone. The guardian was appointed solely on the ground of Coena’s habits of intoxication and might be entirely consistent with the possession of testamentary capacity or even of extraordinary mental endowments. While the fact of the guardianship on the ground of intemperate habits would be evidence for the jury to consider as bearing on her mental condition, yet we do not think that the fact of the guardianship on this ground would raise the same presumption of testamentary incapacity as would have been the case had the guardianship rested upon the ground of insanity or imbecility, or any other form of mental weakness or disease.

There may have been evidence of mental weakness given at the trial, but that we know nothing about. We are deciding the question before us purely on the presumptions sought to be raised by the appointment of the guardian and the employment by him of Mrs. Welsh to take care of his ward and the relations of friendship and intimacy thus established. We do not think that the mere fact of employment of Mrs. Welsh and the friendly relations thus established, is sufficient of itself to raise a presumption of undue influence on the part of Mrs. Welsh, at least not without some evidence tending to show that such friendly relations were abused, or exerted in some way to influence the •making of the will. We do not think that Mrs. Welsh stood in the shoes of the guardian in this respect.

[412]*412Supposing, however, that “we are wrong in this conclusion, and that a presumption of undue influence is raised against Mrs. Welsh by the fact.of her relationship to Coena Murphy. What is the degree of proof required to rebut the presumption? The issue in a will contest is simplified by statute to the single question : Is the paper in question the last will and testament of the testator? The party sustaining the will has the right to open and close the evidence and the argument. He must offer the will and order of probate thereof and rest his ease. The order of probate is prima facie evidence of the due attestation, execution and validity of the will. By these provisions of the statutes, which I have thus summarized, it is sure that the only burden resting on the party sustaining the will is to offer certain evidence which the law requires to make a prima facie case sustaining the will. The burden then rests on the contestants to prove something necessary to render the will invalid. Are the contestants relieved of this burden at any stage of the trial?

We think not. While it may happen that in the course of the trial some issue may arise, the burden of which would rest upon the party sustaining the will, the general burden of proof, as to those things which render the will invalid, does not change. The degree of proof required to. rebut a presumption is not a preponderance of' the evidence, but evidence equal in countervailing weight to the effect of the presumption. In Klunk v. Hocking Valley Ry., 74 Ohio St. 125 [77 N. E. 752] the action was by a locomotive engineer to recover for injuries sustained by the breaking of a water guage, the breaking of which raised a prima facie presumption of negligence. In the second proposition of the syllabus it is said:

“Proof of facts sufficient under the statute to create a prima facie presumption of negligence against the defendant east upon it the burden of producing evidence of equal weight or countervailing force, in order to control or destroy the presumption, yet proof of such facts does not impose upon the defendant the burden of establishing affirmatively by a preponderance of the evidence, that it was not negligent. ’ ’ Hutson v. Hartley, 72 Ohio St. 262 [74 N. E. 197].

We think these cases settle the question that the burden of [413]*413proof in a will contest does not shift as to any question at issue necessary to establish the invalidity of the will. The contestants in the fifth, proposition to charge before argument, asked the.

Free access — add to your briefcase to read the full text and ask questions with AI

Cite This Page — Counsel Stack

Bluebook (online)
32 Ohio C.C. Dec. 409, 19 Ohio C.C. (n.s.) 177, 1909 Ohio Misc. LEXIS 439, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fagan-v-welsh-ohcirctcuyahoga-1909.