Harris v. Maholm

20 Ohio N.P. (n.s.) 439
CourtLicking County Court of Common Pleas
DecidedJuly 1, 1918
StatusPublished

This text of 20 Ohio N.P. (n.s.) 439 (Harris v. Maholm) is published on Counsel Stack Legal Research, covering Licking County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harris v. Maholm, 20 Ohio N.P. (n.s.) 439 (Ohio Super. Ct. 1918).

Opinion

Blair, J.

(Knox County).

The second item of the will of J ames Maholm reads as follows:

“Item 2. I devise and bequeath to my son, Thomas T. Maholm, and to the heirs of his body forever, the farm that he now resides upon, southwest and adjoining the village of Chatham, containing 195 acres more or less: for description of said farm see deed from Ashelman, now on record in the recorder’s office of Licking county, Ohio; the design of this item 2d is to confine the title of this farm to my son Thomas, and to his children and to their heirs down the same line forever.”

This will was duly admitted to probate and record in the Probate Court of Licking County, Ohio, and in 1870, and within the time allowed by law this son, Thomas T. Maholm, filed suit in the Court of Common Pleas of Licking County to contest such will, and as a result procured a verdict of a jury and judgment of the court setting the will aside.

Thereupon the brothers and sisters of Thomas gave Thomas quit-claim deeds to the farm described 'in item two of their father’s will; and Thomas in turn quit-claimed all his interest in other tracts to his brothers and sisters. By the terms of his will, the father had made provisions for the other children substantially as he had for Thomas, i. e., he had entailed certain lands to each of the other children and the heirs of their bodies, but in somewhat different language from that used in the entailment to Thomas and the heirs of his body.

As a result of the judgment setting aside the will, .and the quit-claim deeds, the children took and held the same parcels of land respectively as were devised to them by their father’s will, [441]*441the title thus obtained being more to the liking of these children than the one conferred upon them by the will of their father. In fact, the real object and purpose of the will contest and quitclaim deeds seems to have been to defeat the entailments.

That such was the object and purpose of these children is borne out by the fact that they had such an understanding and agreement among themselves before the will contest was heard, and no effort was made by any of them to sustain the will.

Thomas thereafter mortgaged this land to the Michigan Mutual Life Insurance Company, and later this company purchased the same at sheriff’s sale, in a suit brought to foreclose a mortgage which had been given by the testator, James Maholm, and in which suit this insurance company was a party defendant, and set up its mortgage given by Thomas. Title to these lands is now claimed by the defendants, Blime and Hunter, through deeds from this insurance company.

Thomas died in the year 1905, and the plaintiff here, who is a daughter of Thomas, now seeks partition of this land among the four children of Thomas who survive him, claiming title under their grandfather’s, will. The defendants, Blime and Hunter, claim that plaintiff and the other children of Thomas are barred from claiming title:

First. Because of the verdict of the jury and judgment of the court in setting aside the will of James Maholm.

Second. Because of the judgment of the common pleas and circuit courts of this county dismissing the petition in a suit brought by these children of Thomas, praying for the vacation of the judgment setting aside the will of their grandfather.

Third. Because of the judgment and sale in the suit of Patton against Maholm, this being a suit to foreclose a mortgage given by the testator, James Maholm, in his lifetime.

Fourth. Because of the statute of limitations.

I have considered these questions in the order in which they were presented. These four children of Thomas (plaintiff and her brothers ,and sister) were all in being and living with their father and mother at the time of the rendition of the judgment setting aside their grandfather’s will (being then minors of ten[442]*442der age), but none of them were parties to such proceeding. The one, James T. Maholm, was named as a defendant in the proceeding, ostensibly because of a small legacy left him by such will; but as the service of summons upon him was fatally defective (and as I recall no guardian ad litem, was appointed) we may safely conclude that none of these children were parties to such suit.

Under these circumstances we are led to inquire, “Is this judgment binding upon these children?” In my judgment, this question must be answered in the negative. Under the will of their grandfather, and by virtue of Section 8622 of the General Code (R. S., 4200), the remainder in fee simple would pass to such of the children of Thomas as should survive him. It is my judgment that these children of Thomas were necessary parties to the will contest proceeding, and not having been parties, they are not in any way affected by the judgment.

Section 12080 of the General Code specifies who must be made parties to a petition to contest the validity of a will. It says:

“All the devisee's, legatees, and heirs of the testator and other interested persons, including the executor or administrator, must be made parties to the action.”

It is claimed on behalf of the defendants, the Blimes and Hunters, that these children of Thomas were not “interested parties” such as is= contemplated in this section of the General Code; that inasmuch as they had no vested interest they would not come within the meaning of the statute; that in all proceedings involving an estate tail, the first tenant in tail represents his issue as well as himself, and that therefore the children or issue of Thomas were represented by Thomas in this proceeding.

There are some old .authorities which at first glance would seem in a measure to support such doctrine, but on closer examination we find such doctrine to have been recognized in eases where the interests of the first donee in tail and that of his issue were identical. In the case at bar it is very different.. The position which Thomas took in the will case was antagonistic to the interest of his children. His own issue were in fact the only p,ar[443]*443ties lie was fighting. Had. Thomas tried to uphold his father’s will and thereby sustain his own as well as his children’s title there would be some reason in claiming that he represented his children in such suit. He was trying to establish his own title as heir and thereby defeat his children or issue of their rights under the will.

I think the doctrine of representation by the first donee in tail against the policy of the law of Ohio. As reflecting upon this question, I cite Section 11925 and the following sections of the General Code which provide for the sale of entailed lands. Section 11926 provides as follows:

“All persons in being who are interested in the estate, or by the terms of the will, deed, or other instrument creating the entailment or other estate thereafter, or otherwise, shall be made parties to the action. ’ ’

These sections were in force substantially in their present form at the time this will was set aside, and show clearly that the Legislature of this state recognized the issue of the tenants in tail as being “interested persons” when it comes to a disposition of an entailed estate, and that in such ease the tenant in tail in no way represents his issue then in being.

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Bluebook (online)
20 Ohio N.P. (n.s.) 439, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-maholm-ohctcompllickin-1918.