Fleming v. Morningstar

4 Ohio N.P. (n.s.) 405, 17 Ohio Dec. 430, 1904 Ohio Misc. LEXIS 153
Darke County Court of Common Pleas·Decided March 6, 1904·Published·Cited by 1 cases

Opinion

Allread, J.

The controverted question here is the claim of Mrs. J. H. Morningstar to dower in a fourteen-acre tract of land sold by the administrator as part of the estate of her late husband.

This tract with others constituted the W. PI. Morningstar estate, which upon his death in 1886, descended to J. IT. and Alice Morningstar (now Fleming) in equal moieties.

There was a mortgage upon certain of the tracts given by the ancestor, and which is known in this case as the “Walker” mortgage. J. IT. and Alice Morningstar gave a mortgage also upon certain of the tracts, known as the “Bachman” mortgage. The fourteen-acre tract was not included in either mortgage.

On July 1, 1889, for the purpose of amicable partition, the tenants in common agreed upon a division of the several tracts of the W. IT. Morningstar estate, and each tenant in common released by a quit-claim deed the undivided half of the tracts allotted in severalty to the other. The allotment to J. II. Morningstar was valued at $6,300; this included the fourteen-acre tract valued at $2,100. The allotment to Alice was valued at $3,200. This would leave a balance upon allotment due her of $1,550.

Alice assumed the “Walker” mortgage of $1,128.65 and J. PI. assumed the “Bachman” mortgage of $1,539.75. The difference in the amount of the-mortgages assumed was in favor of J. PI., $205.50, reducing the actual purchase money due Alice on the.exchange to $1,344.50.

In their settlement, however, the purchase money of the tracts was mingled with other items and there was found due Alice bji- settlement, after deducting the excess of the mortgage assumed by J. IT., $1,866.40. On the date of the partition deeds, a mortgage was given by J. PI. to Alice Morningstar on the fourteen-acre tract for $1,500, reciting it to be for purchase money. No very clear evidence is forthcoming as to the discrepancy between $1,866.40 and $1,500, the amount of the mortgage, but [407]*407an inference arises that this amount was settled either by mutual accounts not shown or by cash payment.

The partition deed to Alice was signed by the wife of J. H. releasing dower, but she did not join in the morigage. The $1,500 mortgage is now asserted by Alice and claimed to be superior to the dower of Mrs. Morningstar, and to be in fact a purchase-money mortgage upon the entire interest in the fourteen-acre tract.

Counsel do not differ materially as to the principle governing a vendor’s lien, but the difficulty arises in applying the principle to a ease of amicable partition. As to the property sold the equity of the vendor attaches at the very instant of the conveyance and is therefore superior to the dower. And the controversy here arises out of the character and nature of the dower interest attaching it to the estate of the tenant in common, as affected by the partition.

There is a clear distinction between estates in joint tenancy as existing at the common law and estates in common. In the former the estate of all the joint tenants was regarded as one estate and no dower attached, but in case of tenancy in common each co-tenant had a separate freehold estate, and inchoate dower in the latter ease attached to the undivided interest immediately upon seizin of the husband. But such right of dower was subject to the right of partition by the co-tenants.

Tracing the legal title alone it would appear that J. II. Morningstar acquired one undivided half of this fourteen-acre tract by descent and one undivided half by purchase from Alice, the former having been acquired in 1886 and the latter in .1889.

It is claimed that a different principle applies in ease of partition and that the difference in the value of the shares taken in severalty is a prior lien upon the larger purpart.

Partition may be cither by judicial or voluntary proceedings If by judicial proceedings the dowress is bound by the partition and her right attaches to the land apparted, or if the land can not be apparted, and is sold, the dower is divested and her right, if any, is transferred to the fund. Weaver v. Gregg, 6. O. S., 547; Gillett v. Miller, 12 C. C., 209.

[408]*408In case of voluntary partition where equal shares are set off to the parceners the weight of authority is to the effect that the right of dower upon the co-tenant’s share is remitted to the allotment in severalty. Carter v. Day, 59 O. S., 101; First Scribner on Dower, Sec. 341; Doeterman v. Elder, 27 Bull., 195.

It is claimed with much force and supported by a carefully and well prepared brief and argument that the same effect must be given to an amicable partition as to a judicial proceeding, and if dower is divested in the latter no less effect should be given to deeds of partition, especially as against the amount necessary to equalize the shares.

Dower is a statutory right. The statutes which give dower also divest it in certain contingencies. Weaver v. Gregg, supra.

No statute expressly divests dower on amicable partition, and hence such contention must find support in other authority.

It is argued that the difference in value between the larger and smaller purparts or divisions is a lien on the larger on the principle of owelty of partition, a doctrine originating in the chancery practice in England, and now recognized by statutes in many states. This doctrine is applied where it is impossible or impracticable to divide the estate in equal shares, and unequal allotments are therefore made subject to a charge upon the greater. Owelty of partition does not exist in this state as a statutory right. Where equal shares can not be allotted the entire estate is required to be sold and the proceeds distributed. But even if recognized in a case where the unequal division is made by consent, it yet remains to be considered what the effect of such a division has upon the inchoate dower of the wife of the tenant in common.

Owelty of partition where it exists is in the nature of a’vendor’s lien; but is it superior to dower?

The case of Mosher v. Mosher, 32 Maine, 412, supports the view that the inchoate dower attaching to the interest of the co-tenant acquired by descent is not affected by such lien. See, also, 11 Amer. & Eng. Enc. of Law, page 118; Hordy v. Landrum, 5 S. C., 213.

In Thomas v. Bank of Maryland, 32 Md., 58, the real estate descended to four children and by agreement was divided among [409]*409three with a charge in favor of the fourth for her share. One of the three became involved and assigned without having paid the amount charged. It was held that the lien for such charge arising in the division of the estate rested only on the one-fourth interest acquired by purchase from the heir in whose favor the lien was claimed and not upon the three-fourth interest acquired in part by descent and in part by purchase from the other heirs.

Freeman in his work on Co-tenancy and Partition (Section 411), in reference to the rights of the wife of a co-tenant, says:

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Fleming v. Morningstar, 4 Ohio N.P. (n.s.) 405, 17 Ohio Dec. 430, 1904 Ohio Misc. LEXIS 153 (Ohio Super. Ct. 1904).

4 Ohio N.P. (n.s.) 405 (Fleming v. Morningstar) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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