Henry v. Leech

3 Balt. C. Rep. 290
CourtBaltimore City Circuit Court
DecidedNovember 29, 1913
StatusPublished

This text of 3 Balt. C. Rep. 290 (Henry v. Leech) is published on Counsel Stack Legal Research, covering Baltimore City Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henry v. Leech, 3 Balt. C. Rep. 290 (Md. Super. Ct. 1913).

Opinion

BOND, X—

John Welsh, a farmer, about 82 years of age at the time of the events of which this controversy has arisen, and in poor health, had for some years previous to November, 1912, lived a retired, solitary life in Baltimore county. He had a married daughter, Mrs. Leech, and a grandson, Timothy Edgar Henry, by a deceased daughter; but he had little communication with them —had had no communication at all with them for a long period of time. He had an estate of over $3,000, all of it in money in a savings bank account. By living alone, most parsimoniously, almost in squalor, if some of his neighbors are to be believed, he managed to live on without labor. He was eccentric. But whether his strange acts were instances of general mental infirmities is a subject of dispute between the witnesses.

In November, 1912, he entered St. Joseph’s Hospital in Baltimore, and remained there for a month under treatment. He was suffering from nephritis and heart trouble, and from time to time had sharp “sinking spells,” as the witnesses described them, which lasted two or three days at a time. On November 25, 1912, he went from the hospital to the house of his daughter, Mrs. Leech, and asked her if she would take him in and give him a home for the rest of his days. She had not known of his being in the hospital. Having her consent he returned to the hospital, and, after having remained there two days longer, came on November 27 to the daughter’s house. On that night he had such an attack of illness that he was thought to be dying; and about midnight a priest was called and the last rites of the church were administered to him. He did not die then, however; was in better condition on the next day; and lived on, indeed, until the following April.

On the morning of November 29, the daughter’s husband procured from the savings bank a blank form of order for payment of the fund, filled it out for payment to his wife, obtained the old man’s signature, properly witnessed, and had the fund transferred accordingly. It was shortly invested in the redemption of the ground rent upon the defendants’ dwelling, owned by them. On December 7 a confirmatory statement, designed to fortify this [291]*291transfer against attack by other relatives, was prepared by attorneys and signed and acknowledged by Welsh, before disinterested witnesses who satisfied themselves as to his full understanding and his wish in the matter.

And now, the old man being dead, his infant grandson applies to have the transfer of money to the daughter declared void, to have the court assume jurisdiction of the fund, and for an accounting of its use, all on the ground that the old man had not the mental capacity to make a valid transfer or gift, and that it was procured by the exercise of fraud and undue influence. No letters of administration have been taken out by the estate of the decedent. His daughter is the person entitled to appointment as administratrix, and she denies that there is any estate. No question has been raised as to the right of the grandson to bring this proceeding; and the case has been contested fully on the question of the validity of the gift.

I do not think the testimony proves that the man, acting independently at least, was mentally incapable of making a valid deed or contract. That he was eccentric was admitted by all the witnesses; and that no rational explanation can be given for some of his acts seems also to be clear. But during most of the time his actions and his conversation seem to have been rational, and not remarkable. More than is shown here is needed to enable a court to adjudge a donor mentally incapable of comprehending the nature and effect of his gift.

In considering the effect of the testimony on the averment of fraud or undue influence in the procurement of the gift it is necessary to determine first of all the character of the relation between the parties to the gift when it was made. It is settled law that if the beneficiary in such a transaction, a gift inter vivos, occupies a confidential relation to the donor, then the gift will be held void, unless the court shall be satisfied that it was the voluntary act of the donor and was not procured by undue influence exercised over him by the donee, the burden of this proof being cast upon the donee. And the plaintiff urges that the relationship of parent and child has always been treated as a confidential one within the meaning of this rule, and, as I understand the argument, concludes that by reason of that relationship alone the court should set aside the gift in this case unless it is clearly shown to have been proper. But I am afraid that argument does not state the whole problem of the case.

There are relationships which by their nature involve the element of confidence and trust by one person in' another; and in dealing with these no direct testimony of the existence of that element is needed. The court may begin at once by requiring explanation and justification of any gift to the trusted person. Outside of these relationships, in all those which do not by their nature involve trust and confidence, the court has no ground for assuming it, and can find it only upon proof. The relation of parent and child is one of the most familiar of those of the first class, by their nature confidential. But the trust assumed to exist is that by a child in its parent; and gifts to the trusted parent are those which are subjected to the unfavorable presumption. It is only by reversal of the natural order that a parent comes under the dominion of a child; and the court cannot begin by assuming that. It must be proved, if it is a fact.

Highberger vs. Stiffler, 21 Md. 338.

Zimmerman vs. Bitner, 79 Md. 115.

Where the elment of confidence must be proved it need not always be shown by evidence of some actual exhibition of it. The situation of the parties and surrounding circumstances may sometimes inferentially show the donor to be under the dominion of the donee as clearly as would direct evidence of such dominion.

Here there is no direct evidence of a confidential relationship. And the circumstances rather disprove the existence of it. The parties had had no intercourse at all for a long time previous to the gift, and until two days before it. Indeed, in respect to the old man’s small business affairs, in respect to any of his interests, there was not, as far as the evidence shows, any relation at all outside of this particular transaction. And this transaction, therefore, however much it may have resulted from ove.rreaching, cannot be said to have taken place between persons who stood in a confidential relation. The court cannot, I think, begin its inquiry by saying to [292]*292the defendants that there was a stewardship, and that this fact requires an accounting.

Wise vs. Swartzfelder, 54 Md. 292.

The plaintiff must, therefore, sustain the burden of proof of the charge of undue influence in the procurement of the gift.

Direct evidence of the undue influence is not required. Naturally a covert action, it can in many cases be proved only by circumstantial evidence.

The circumstances here give rise to strong suspicions of undue influence and the lack of free voluntary action on the part of the donor. And the question of the effect of the proof seems to me a close one. But I have concluded that the evidence does not prove undue influence, and does not enable the court to set the gift aside.

We have on the one hand these suspicious facts: The donor was old, enfeebled in health, and to some extent in mind.

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Related

Highberger v. Stiffler
21 Md. 338 (Court of Appeals of Maryland, 1864)
Wise v. Swartzwelder
54 Md. 292 (Court of Appeals of Maryland, 1880)
Zimmerman v. Bitner
28 A. 820 (Court of Appeals of Maryland, 1894)

Cite This Page — Counsel Stack

Bluebook (online)
3 Balt. C. Rep. 290, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-v-leech-mdcirctctbalt-1913.