Hahn Estate

7 Pa. D. & C.3d 438, 1978 Pa. Dist. & Cnty. Dec. LEXIS 260
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedJuly 11, 1978
Docketno. 74711
StatusPublished
Cited by1 cases

This text of 7 Pa. D. & C.3d 438 (Hahn Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hahn Estate, 7 Pa. D. & C.3d 438, 1978 Pa. Dist. & Cnty. Dec. LEXIS 260 (Pa. Super. Ct. 1978).

Opinion

TAXIS, J.,

This matter is before the court upon a request by Earle Hahn (Earle) as personal representative of the Estate of Arthur Hahn (Arthur), deceased, to strike the election of Sylvia Hahn (Sylvia) against the will and lifetime conveyances of Arthur. Also before the court are objections filed by Sylvia to the inventory filed by Earle.

Arthur died on June 18,1973, survived by his son, Earle, by a first marriage, and his widow, Sylvia. Arthur and Sylvia were married on August 28, 1949, and on January 10, 1961 (eleven-and-a-half years later), Arthur and Sylvia signed a post-nuptial agreement. The parties were living together as husband and wife when this agreement was executed and continued to do so up until the date of Arthur’s death.

After decedent’s death, Sylvia filed her election to take against decedent’s will and his inter-vivos conveyances and Earle seeks dismissal of her election, claiming that the widow is barred by the post-nuptial agreement. Sylvia, on the other hand, claims that the post-nuptial agreement is void and unenforceable because Arthur failed to make a full and fair disclosure of his assets at that time.

[441]*441The post-nuptial agreement is presumptively valid and binding upon the parties thereto and in order to nullify or avoid or circumvent the agreement, Sylvia has the burden of proving the invalidity of the agreement by clear and convincing evidence that Arthur did not (1) make a reasonable provision for her at the time of the agreement, or (2) in the absence of such a provision, make a fair and full disclosure to her of his worth at that time: Hillegass Est., 431 Pa. 144, 244 A. 2d 672 (1968).

A reading of the agreement of January 10, 1961, clearly establishes that there is no provision made for Sylvia. A unique argument, however, is made by Earle that a reasonable provision for the wife can be contained in an instrument other than the post-nuptial agreement, provided it is made at the same time; that Arthur executed a will at the same meeting in which he signed the post-nuptial agreement; and that such will, the terms of which are unnecessary to recite here, does make provisions for Sylvia. This court concludes that the reasonable provision for the wife must be contained in the post-nuptial contract because then, if the post-nuptial contract is valid, the reasonable provision for the wife is enforceable. Arthur, however, provided for his wife in a will, which is of no value until his death, and then only if it is, in fact, his last will and testament. The reason for the rule that the reasonable provision must appear in the post-nuptial agreement is vividly demonstrated here because Arthur, before he died, executed a holographic will giving everything to his son, Earle, and revoking the will which had made provisions for his wife.

We now turn to the question of whether or not Arthur made a full and fair disclosure to Sylvia at the time of the signing of the agreement. See [442]*442Ratony Est., 443 Pa. 454, 460, 461, 277 A. 2d 791 (1971); Hillegass Est., supra.

It is true that paragraph 3 of the agreement states that: “Each spouse has disclosed to the other a full and complete statement of his or her assets and liabilities as of the date hereof, and such full disclosure is acknowledged by each of the parties as evidenced by the execution of this agreement.” This clause is prima facie evidence that a full and fair disclosure of decedent’s assets were made. Sylvia must prove the absence of full and fair disclosure by clear and convincing evidence.

Proof of clear and convincing evidence does not require proof beyond a reasonable doubt, although it does require proof greater than a mere preponderance: Ziel Est., 467 Pa. 531, 359 A. 2d 728 (1976).

Before a recitation of the testimony establishing the nondisclosure by Arthur, the court at this point rules that Sylvia’s testimony as to nondisclosure is inadmissible under the Dead Man’s Rule. See Vallish Est., 431 Pa. 88, 98, 244 A. 2d 745 (1968). The argument on behalf of Sylvia that the rule was waived by the production of other witnesses by Earle is without merit, and the court concludes that the production of these witnesses was not a waiver of Sylvia’s incompetency. Cf. Moore Est., 439 Pa. 578, 266 A. 2d 641 (1970); Rosche v. McCoy, 397 Pa. 615, 156 A. 2d 307 (1959); Volkwein v. Volkwein, 146 Pa. Superior Ct. 265, 22 A. 2d 81 (1941).

Turning now to the testimony that bears upon the question of nondisclosure, this record establishes the following facts. Arthur sought assistance in the preparation of a will for himself and his wife and in the preparation of a post-nuptial agreement. Arthur called the Fidelity Bank, and James J. Coate, Esq., [443]*443was assigned to the matter. Because Arthur did not want his personal attorney, Raymond Pearlstine, Esq., to have anything to do with the preparation of these instruments, Arthur instructed Mr. Coate to select an attorney, and John D. Lucey, Esq., was selected. The testimony of Mr. Lucey and Mr. Coate in points relevant here is important.

Mr. Coate was questioned about a copy (Exhibit R-87) of the post-nuptial agreement taken from the file of LaBrum & Doak, Esqs., which contained a page with (a) a date and signature place for Sylvia at the bottom, and (b) a statement at the top, “I acknowledge that the following assets of Arthur Hahn have been disclosed to me,” the rest of the page being blank. The testimony was as follows:

“Q. . . On January 10,1961, were the documents as signed by Arthur and Sylvia, Hahn . . . with respect to whether or not there was attached to the document a last page for the signature of Sylvia Hahn concerning assets of Arthur Hahn?

“Was that page on the documents at the time of the signing?

“A . . . To my recollection, no, it was not. . .

“BY THE COURT:

“Q What is your best present recollection?

“A My best present recollection is that the page was not there, but I can give some further explanation of that.

“BY MR. AKER:

“Q Would you give your further explanation, then? . . .

“A ... it was clearly stated by me to Mr. Hahn that these kinds of agreements, without a revelation of assets, and attached as an exhibit to this kind of post-nuptial agreement — that this kind of [444]*444agreement could very well be unenforcible, or ruled invalid, because of failure to reveal assets, and at that time it was sort of brushed off, like, ‘Don’t get into it any further. It’s okay the way it is. We will add that later.'

“Q Brushed off by whom?

“A By Mr. Hahn.

“Q During the meetings with Arthur Hahn prior to January 10, 1961, was the document ever presented to Arthur Hahn with that last sheet that appears as a part of Exhibit R-87 presented to him for his consideration?

“A I don’t know if anything was presented to him by way of a writing. He was certainly told that this had to be part of the agreement ”

Both James Coate and John Lucey confirmed the fact that Sylvia had not been present at any of the meetings at which preparation of the post-nuptial agreement was discussed, and that Sylvia was never represented by separate counsel relative to the post-nuptial agreement.

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Bluebook (online)
7 Pa. D. & C.3d 438, 1978 Pa. Dist. & Cnty. Dec. LEXIS 260, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hahn-estate-pactcomplmontgo-1978.