Heckman v. Adams

50 Ohio St. (N.S.) 305
CourtOhio Supreme Court
DecidedMay 9, 1893
StatusPublished

This text of 50 Ohio St. (N.S.) 305 (Heckman v. Adams) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heckman v. Adams, 50 Ohio St. (N.S.) 305 (Ohio 1893).

Opinion

Burket, J.

The whole case turns upon the single question, whether or not the appointment of Mr. Heckman as guardian of the estate of Mrs. Adams, was void or valid.

Mr. Adams and his wife were married, and the property in controversy acquired, while section 3108, of the Revised Statutes, as amended April 16, 1885, and section 3109, as amended April 14, 1884, were in force.

Section 3108, provides as follows:

Any estate or interest, legal or equitable, in real or personal property, including rights in action, belonging to a woman at her marriage, or which may come to her during coverture, by conveyance, gift, devise or inheritance, or by purchase with her separate money or means, or due as the wages of her personal labor, or growing out of any viola[311]*311tion of her personal rights, shall, together with the rents, incomes, issues and profits thereof, be and remain her separate property.” There is a further provision in this section as to his curtesy in her real estate, and as to her leasing the same, but nothing further as to personal estate.

Section 3109, is as follows:

■ “The separate property of the wife shall be under her-sole control, and shall not be taken by any process of law for the debts of the husband, or be in any manner conveyed or incumbered by him, and she may, in her own name, during coverture, contract to the same extent and in the same manner as if she were unmarried.”

Under and by virtue of these two sections, the separate property of the wife belongs to her in her own right, and is under her sole control, and the husband as such, has no interest in or control over the same.

As to the wife’s separate property, the husband stands as a stranger to her. While the case of Levi v. Earl, 30 Ohio St. 147, has been overruled as to another point, it has never been doubted as to the point here in question. In that case this court held that the separate property of the wife, as fixed by the married woman’s act of 1861, as amended in 1866, became by virtue of that statute her separate property and under her sole control, “free from the marital rights of the husband at common law over the same.” And' this court further held in the same case that, “ By these statutes the marital rights of the husband were divested as to the wife’s general estate, and the wife was invested with the control of the same,” In the case of Patten v. Patten, 75 Ill., 446, the court says: “The effect of the married woman’s act is such that the rights of the husband at common law, in respect to the wife’s property, are swept away and gone. As to her separate estate, and her relations thereto, she has no husband, and he is as to such estate, even during coverture, a stranger.”

Of course, these statutes as to the rights of married women, do not affect or change the common law rule, that in the absence of the husband, the wife is his agent for the care and protection of his property. And as a necessary [312]*312result of these statutes the husband is now held, in the absence of the wife, to be her agent for the care and protection of her property. While thus acting fpr her in her absence, his rights and relations to her property are the same as hers were to his property, at common law, under the same circumstances.

The legal effect of the statutes as to the property rights of married women is to place husband and wife upon an exact equality as to the property of each, that is, “ Neither husband nor wife has any interest in the property of the other,” except as to dower, distribution and support. It therefore follows that Mr. Adams had no interest in or control over the property of his wife as against her or her representative. Mr. Pleckman claimed to be her representative, her guardian, and Mr. Adams claimed that the appointment of Mr. Heckman as guardian of Mrs. Adams was void, for the reason that Mr. Adams had no notice of the application for the appointment of a guardian for his wife; and he offered on the trial to prove that he had nO' such notice. The court refused to admit the testimony on that point, and exceptions were duly taken. The court also charged the jury that if Mr. Heckman was appointed and qualified as guardian of Mrs. Adams, that he was entitled as such guardian to the property in controversy; and had the right to take the property from the possession of any person who refused to deliver the same to him on demand; to which charge exceptions were taken by Mr. Adams.

The appointment of Mr. Heckman as guardian of Mrs. Adams, was for her estate only, and not for her person and estate; and it is claimed that under section 6302 there is no authority for the appointment of a guardian of the estate only of a lunatic.

. Section 6304 provides that: “All laws relating to guardians for minors and their wards, * * in force for the time being, shall be applicable to guardians for * * lunatics * * except as otherwise specially provided.”

Section 6255 was in force for the time being at the time of this appointment, and that section provides that: “ A [313]*313guardian may be appointed to take charge only of the estate of a minor.”

The appointment of a guardian for the estate only of a lunatic, it will thus be seen, is authorized by the letter of these two sections of the statute.

Section 6302 is made up in the revision of 1880, out of sections 41, 43 and 44 of the act of April 7, 1856. Section 41 provides that the probate judge upon satisfactory proof that any person resident of the county, is an idiot or lunatic, and that it is necessary in order to preserve the property of such idiot or lunatic, shall appoint a guardian.

Section 43 was in the same words except that the words, “ and that it is necessary in order to preserve the property” were omitted.

The guardian to be appointed under section 41 was for the preservation of the property, that is of the estate only, while the appointment under section 43 was general, for both person and estate.

As these two sections are now combined into one (6302) the new section must be construed to be as broad as both of the old ones taken together. The new section is more general in its terms, but not more narrow in its provisions.

In the case of King v. Bell, 36 Ohio St. 460, this court held, that all laws relating to guardians for minors and their wards are made applicable to guardians for lunatics.

True, the question as to appointing a guardian for the estate only of a lunatic, did not arise in that case; but the question as to whether the appointment of the guardian for the lunatic, who was also a minor in that case, was, or was not, authorized by said section 6304, was directly in question, and said section was held to be applicable, and to give such authority.

In the case of Martin L. Leffel v. Henry C. Knoop, decided at the present term of this court, and not reported, this court held, that sections 6304 and 6255 applied to the appointment of guardians for lunatics, and that such guardians might be appointed for the estate only. We still regard that decision correct, and therefore hold that the statute [314]*314authorizes the appointment of a guardian for the estate only of’ a lunatic or insane person.

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Related

McCurry v. Hooper
12 Ala. 823 (Supreme Court of Alabama, 1848)
Eslava v. Lepretre
21 Ala. 504 (Supreme Court of Alabama, 1852)
Patten v. Patten
75 Ill. 446 (Illinois Supreme Court, 1874)

Cite This Page — Counsel Stack

Bluebook (online)
50 Ohio St. (N.S.) 305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heckman-v-adams-ohio-1893.