Fitzgerald v. Harris

92 Va. Cir. 451, 2012 Va. Cir. LEXIS 213
CourtAugusta County Circuit Court
DecidedJune 27, 2012
DocketCase No. CL06001278-00
StatusPublished

This text of 92 Va. Cir. 451 (Fitzgerald v. Harris) is published on Counsel Stack Legal Research, covering Augusta County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fitzgerald v. Harris, 92 Va. Cir. 451, 2012 Va. Cir. LEXIS 213 (Va. Super. Ct. 2012).

Opinion

By

Judge Victor V. Ludwig

The case before the Court arises from a complaint for partition filed by Gail D. Fitzgerald and Kirk D. Dedrick against Sheila D. Harris, Dixie L. Dedrick (Dedrick),1 and others, seeking partition of real property devised by Valda F. Dedrick as part of her estate (the Estate). In response to the complaint for partition, Dixie, “individually and as Executor of the Estate,” moved for “aid and guidance in the completion of her administration of the” Estate, in part because the funds remaining in the Estate were insufficient for the satisfaction of claims, existing and potential.

The plaintiffs in the partition suit filed a demurrer to the counterclaim which does not appear ever to have been formally addressed. There is an order in the file, as to which Mr. Watkins gave notice of entry on January 29, 2007, dismissing the demurrer by agreement, but I cannot find that the order was entered. Nevertheless, on November 6, 2007, the Court entered an order requiring the issuance of process on additional parties as to “the complaint and counterclaim,” from which I conclude that the demurrer was not pursued and was never sustained and that the case proceeded with both pleadings to be resolved. By the time I became responsible for the suit in 2008, that appeared to be the undisputed posture of the case.

The suit for partition, inextricably tied to the administration of the Estate, has been on going, with the most recent full hearing having been on August 9, 2011, with the last written information having been presented in January 2012, and the last appearance of the matter on the Court’s docket having been in March 2012.

[452]*452 A Lingering Issue of Attorney’s Fees

Although I believe that I have put to rest the issue of Harris’ claim against the Estate for attorney’s fees expended in an earlier suit which was resolved by order of March 6, 2006, Gail D. Fitzgerald et al. v. Dixie L. Dedrick, Executrix, et al., CH04000583, the still pending case has created sufficient ill-will that I do not want matters to be exacerbated by what might be perceived as a cavalier or thoughtless dismissal of those claims. The result is the same as I have already announced, so the loss of faith in the process may not be restored, but at least one cannot assert that the Court was entirely arbitrary or took the easy way with a knee-jerk reaction and called it black-letter law.

In the earlier suit, Fitzgerald alleged, inter alia, (a) that Harris was in possession of certain personal property belonging to the Estate (as to which the requested remedy is not clear), (b) that Harris and Dedrick had entered into a contract with the decedent regarding insurance proceeds (and maybe some breach of fiduciary duty), and (c) that Harris conspired with Dedrick to deny the beneficiaries of the Estate their rightful shares. Amended bill of complaint, CH04000583. The amended complaint prayed for an award of $100,000.00, joint and several, against Dedrick and Harris. Ultimately, the case was resolved on a motion to strike, a comment on the case’s lack of merit, or, at least, on the presentation (perhaps the existence) of evidence to support it.

There does not appear to be any dispute that Harris significantly contributed to the defense of the claims, evidenced by the fact that, as Mr. Brannock observed, Judge Wood asked him to prepare the order disposing of it. However, it is inaccurate to assert that the Court views Harris only as a volunteer in the case; on the contrary, the Court is keenly aware that she was a party and exposed to liability, not as a representative of the Estate but in her own right. Although Harris might well have elected to permit Dedrick to take the lead, she also might have (and apparently did) elect, instead, vigorously to defend herself. To be sure, her efforts benefited Dedrick (and arguably the Estate) as well, but the ad damnum and prayer for relief touched Harris personally. In that posture, Harris did not act entirely altruistically; without her efforts, had there been any merit to the case, she might have suffered significant financial consequences separate and apart from Dedrick’s or the Estate’s exposure.

As Mr. Brannock acknowledges in his memorandum, Willson v. Whitehead, 181 Va. 960 (1943), does not “address anon-fiduciary.. .placed in [Harris’] position who is sued as a co-conspirator with an Executor.” Harris Letter of September 13, 2011, page 3. Harris does cite Dickenson v. Charles, 173 Va. 393 (1939), in support of her claim, likening herself to a surety seeking reimbursement. However, although there may be an analogy, it is not persuasive. Dickenson surely stands for the proposition that “one secondarily liable on an obligation, such as a surety or an [453]*453accommodation endorser, who has satisfied the demands of the holder, is entitled to reimbursement from the party primarily liable,” id. at 400, but Harris was not a surety for the Estate. In Dickenson (as is generally the case in which a surety is required to stand to his promise), there was no allegation that the surety had any liability other than one resulting from his having agreed to guarantee the principal’s debt. But for the principal’s failure to pay, the surety, who was active in executing the guaranty but passive otherwise, would have had no exposure. In the earlier case in this Court, however, no matter how baseless the claims may have been, it was not only the Estate (the debtor in Harris’ analogy) but the surety (Harris, in her analogy) who was pursued, each for its (or her) own active part in the alleged wrong-doing.

Nor does Colbert v. Priester, 214 Va. 608 (1974), alter the analysis. In that case, Priester’s spouse died intestate, owning the parties’ residence. Because of her intestacy, the decedent’s real estate passed by law to her children of a prior marriage, subject to Priester’s curtesy interest. During the seven years following the death of Priester’s wife, Priester and the Colbert children lived in the residence, and Priester paid the debt which was secured by it. The issue in the case was whether Priester should be reimbursed for the payment of that debt.

For its holding in Colbert, the Court relied on Code § 64.1-33, which permitted Priester to occupy the residence without charge until his curtesy was assigned, and on an earlier holding, Simmons v. Lyles, Adm’r, 73 Va. (32 Gratt.) 752 (1880). In the Simmons case, the Court had concluded that the payment of a debt, during the period after the owning spouse’s death but before the assignment of the dower interest, resulted in the surviving spouse’s having a “right of substitution to the lien” of the lender. Id. at 764. In Priester, recognizing that, as was the case in Simmons, Priester was in possession of the residence pursuant to a right afforded him by statute and that his payment increased the value of the Colberts’ inheritance, the Court concluded that Priester was entitled to reimbursement. Priester’s right to occupy the residence was “a permissive possession that [could] be terminated whenever the [Colberts] elect[ed] to assign . . . curtesy.” Colbert, at 607. He could have vacated the premises, leaving the residence encumbered by the debt, or he could elect to exercise his statutory right to remain, but he could do that only if he made the payments. Priester elected the latter course, with the result that he benefited both himself and the Colberts.

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Related

Simmons v. Lyle's adm'r
73 Va. 752 (Supreme Court of Virginia, 1880)
Dickenson v. Charles
4 S.E.2d 351 (Supreme Court of Virginia, 1939)
Willson v. Whitehead
27 S.E.2d 213 (Supreme Court of Virginia, 1943)
Colbert v. Priester
203 S.E.2d 134 (Supreme Court of Virginia, 1974)

Cite This Page — Counsel Stack

Bluebook (online)
92 Va. Cir. 451, 2012 Va. Cir. LEXIS 213, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fitzgerald-v-harris-vaccaugusta-2012.