Gionfriddo v. Palatrone

196 N.E.2d 162, 93 Ohio Law. Abs. 257, 26 Ohio Op. 2d 158, 1964 Ohio Misc. LEXIS 310
CourtCuyahoga County Probate Court
DecidedJanuary 17, 1964
DocketNo. 643882
StatusPublished
Cited by1 cases

This text of 196 N.E.2d 162 (Gionfriddo v. Palatrone) is published on Counsel Stack Legal Research, covering Cuyahoga County Probate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gionfriddo v. Palatrone, 196 N.E.2d 162, 93 Ohio Law. Abs. 257, 26 Ohio Op. 2d 158, 1964 Ohio Misc. LEXIS 310 (Ohio Super. Ct. 1964).

Opinion

Andrews, Chief Referee.

This is a ease involving abatement. It comes to this court on a petition by the executrix of Frank Palatrone’s will for the construction of the will and related documents. Mr. Palatrone died on August 3, 1961.

The subject of abatement was treated extensively in an unreported opinion written by me in the case of McArthur v. McArthur, No. 605901, Probate Court, Cuyahoga County, August 1, 1961. As stated in Atkinson on Wills, Section 136, page 754 (2d ed. 1953):

“ ‘Abatement’ is the reduction of legacies on account of the insufficiency of the estate to pay testator’s debts and other legacies.”

And as said in 6 Bowe-Parker, Page on Wills, Section 53.1, page 201 (1962):

“The term ‘abatement’ under modern statutes usually applies to the failure of legacies or devises due to insufficiency resulting from any cause.”

See also, for similar, definitions, Ferris v. Jones, 2 Ohio Opinions, 136, 1 Ohio Supp., 233 (Prob. Ct. 1935); Harper v. Society for Crippled Children, 81 Ohio Law Abs., 91, 158 N. E. (2d), 747 (Com. Pl. 1959).

Putting the definition into laymen’s language, we may say that abatement means simply that there is not enough to go round. For this reason the beneficiaries under the will, or some of them, must suffer a loss, in that they will not get all that was given to them by the terms of the will. Indeed, in some instances, depending upon the particular circumstances, one or more of the beneficiaries may get nothing.

The disappointing thing about abatement is that ordinarily neither the testator nor the beneficiaries expect it. If the testator bequeaths $10,000 to his cousin, John Jones, and $5,000 to [260]*260Ms uncle, Harry Smith, it is not likely to occur to these people that conditions may arise under wMch the amount eventually received may be substantially less than the amount called for by the will. Even greater frustration arises when the bequest or devise is “specific,” wMch, as will be seen, is the situation in the present case. As explained in 6 Bowe-Parker, Page on Wills, Section 48.3 (1962):

“A specific legacy is a gift of a specific thing, * * * wMch is so described by the testator’s will as to distinguish it from other articles of the same general nature. A specific legacy differs from a general legacy in that it is not intended by testator to be paid out of Ms estate generally, but is to be paid solely by delivering to the beneficiary the specific thing given by will, as distinguished from a designated value, quantity, and the like.”

The Supreme Court of OMo has defined the term in the same way. In re Estate of Mellett, 162 Ohio St., 113, 121 N. E. (2d), 7 (1954).

Naturally, a devise of realty, propertly identified, is likewise specific. 6 Bowe-Parker, Page on Wills, Section 48.9, p. 33 (1962).

Where, as in the present case, the estate is without cash, and the bequests and devises are all specific, it is obvious that the beneficiaries must receive less than the will contemplated. Realization must be less than anticipation.

In these unpleasant circumstances, there is a tendency among beneficiaries to express disbelief and dismay. After all, they reason, the testator expressed very clearly what he wanted me to have, and so I should have it. There is likewise a tendency to think that the other fellow should bear the loss.

The OMo legislature has set forth how the loss is to be borne. Section 2107.54, Revised Code, reads as follows:

“When real or personal property, devised or bequeathed, is taken from the devisee or legatee for the payment of a debt of the testator, the other devisees and legatees must contribute their respective proportions of the loss to the person from whom such payment was taken so that the loss will fall equally on all the devisees and legatees according to the value of the property received by each of them.
[261]*261“If, by making a specific devise or bequest, the testator has exempted a devisee or legatee from liability to contribute to the payment of debts, or if the will makes a different provision for the payment of debts than the one prescribed in this section, the estate must be applied in conformity with the will.
“This section does not affect the liability of the whole estate of the testator for the payment of his debts. This section applies only to the marshalling of the assets as between those who hold or claim under the will.”

If it be thought that this section completely exempts specific devisees and legatees from contributing to the payment of debts, we have only to look at the last clause, which affirms the liability of the whole estate for the payment of debts. Considering the statute as a whole, it is clear that general legatees and devisees must first contribute to the loss, as against specific legatees and devisees. In that sense, specific devisees and legatees are exempt. But if the fund from the general devises and bequests is insufficient to pay the debts, it is equally clear that the specific devisees and legatees must contribute. That was the situation in McArthur v. McArthur, previously referred to. In the McArthur case, we quoted from Glass v. Dunn, 17 Ohio St., 413 (1867), in which the court pointed out that the statute does not actually exempt specific devisees and legatees from contribution, but merely puts them in a preferred position as opposed to general devisees and legatees.

We held also in McArthur that specific devises and bequests abate together. In other words, devises are not favored over bequests. A careful reading of Section 2107.54, Revised Code, leads to this conclusion. And we cited Huntington National Bank v. Roan, 10 Ohio Law Abs., 500 (App. 1931), so holding, and also 42 A. L. R., 1519 (1926), stating this to be the majority view, and setting forth in the following language what the annotator calls the “obvious” reason:

“Where a testator gives specific chattels or personal property, and also a specific devise of real estate, the courts will not, in the absence of other evidence, presume that he intended to favor one class over the other. He intended that the legatees should have the legacies, and equally that the devisees should [262]*262have the devises. And if both are liable for the debts, the most logical rule is that they should contribute and abate ratably.”

Let us apply these principles to the will of Prank Palatrone. The will was executed on March 15,1961.

By Item I he directs that all his just debts, funeral and burial expenses be first paid out of his estate as soon as practicable after his decease.

Item II incorporates by reference an antenuptial agreement dated April 11, 1959, and continues with the following:

“In conformity with the provisions contained in said agreement, I hereby:”

Thereafter, as (a) in Item II, the testator devises to his two children, Frank, Jr., and Beverly, “the residence property known as 1401 Sunview Road, Lyndhurst, Ohio, share and share alike, absolutely and in fee simple.”

In (b) he gives to his two children, named above, his Ford automobile, in equal shares.

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Bluebook (online)
196 N.E.2d 162, 93 Ohio Law. Abs. 257, 26 Ohio Op. 2d 158, 1964 Ohio Misc. LEXIS 310, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gionfriddo-v-palatrone-ohprobctcuyahog-1964.