Holdren v. Holdren

78 Ohio St. (N.S.) 276
CourtOhio Supreme Court
DecidedJune 9, 1908
DocketNo. 9366
StatusPublished

This text of 78 Ohio St. (N.S.) 276 (Holdren v. Holdren) 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
Holdren v. Holdren, 78 Ohio St. (N.S.) 276 (Ohio 1908).

Opinion

Summers, J.

The contention on the part of the minor son, Stanley Holdren, is that by the will he took a vested estate in remainder, and [280]*280that it was accelerated, and took effect in possession immediately upon the determination of his mother’s life estate, by her election not to take under the will. And the contention on the part of the other devisees is, that the estate devised to the minor son is not an estate in remainder but by executory devise, that it was not accelerated by the election of the widow not to take under the will and that a court of equity will sequester what the widow would have taken under the will to compensate the disappointed devisees.

We do not think it important to consider whether the minor took an estate in remainder or by ex-ecutory devise, for in the view we take of the case the doctrine of acceleration of remainders has no application. That doctrine is based upon the presumed intention of’the testator to devise the property in remainder from and after the determination of the preceding estate, and not from and after the death of the life tenant. It is a rule of interpretation, and is to be applied so as to effect and not to defeat the testator’s intention.

By the fifth item the testator devised the one-sixth part of his real estate to his widow for and during her natural life, and at her death' to his son Stanley in fee simple. In Lessee of Thompson v. Hoop, 6 Ohio St., 487, Bartley, C. J., quotes with approval from 1 Jarman on Wills as follows: “Every devise of a future interest, which is not preceded by an estate of freehold created by the same will, or which, being so preceded, is limited to take effect before or after, and not at the expiration of such prior estate of freehold, is an executory de[281]*281vise.” Counsel contend upon the authority of that case that Stanley’s estate is limited to take effect at the widow’s death, and not at the expiration of her life estate, and that, therefore, his estate is not accelerated by her election not to take under the will. But if the doctrine of acceleration applies, the words, “At her death” must be interpreted to mean from and after the determination of her life estate. In Jull v. Jacobs, L. R. 3 Ch. Div., 711, the devise was to a daughter of the testator “during her life time”, and “after her decease” to be divided equally between “her children on their becoming of age.” The daughter signed the will as a witness, and for that cause, under the English statute, the devise to such daughter was void. The question was as.to the disposition of the property devised, during the period between the death of the testator and the actual death of the daughter. It is there ruled: “That a gift to A for life, and from and after the decease of A, to B, C, D or anybody else, means from and after the determination of the estate; and whether the estate is determined by revocation or by death, or by the incapacity of the devisee to take, or by any other circumstance, the life estate being out of the way, the remainder takes effect, having only been postponed in order that the life estate may be given to A.” In Lainson v. Lainson, 18 Beav., 1, Lord Romily says: “This doctrine rests upon the authorities from the earliest period downwards.” In Blatchford et al. v. Newberry et al., 99 Ill., 11, in the opinion and in the dissenting opinion quite a number of cases are referred to, in which this doctrine is laid down. In 1 Jarman on Wills, 537, [282]*282it is said: “The doctrine evidently proceeds upon the supposition that, though the ulterior devise is in terms not to take effect in possession until the decease of the prior devisee, if tenant for life, or his decease without issue, if tenant in tail, yet that, in point of fact, it is to be read as a limitation of a remainder, to take effect in every event which removes the prior estate out of the way.”

This doctrine, however, is based upon the presumed intention of the testator, and it can be invoked only to effect that intention, and not to defeat it. If the provision made by the testator for his widow was in addition to her dower, or if the termination of her life estate would not disappoint other beneficiaries under the will, the presumption would be that Stanley’s possession had been postponed merely to let his mother enjoy the one-sixth for her life; but there is no room for the presumption where' the provision is not in addition to dower, and where the presumption can be raised only at the expense of other devisees. The testator cannot be presumed to have intended that his widow, by electing not to take under his will, might not only double what she receives from his estate, but also treble what her son will receive. It is true the testator is presumed to have made his will with knowledge that he could not defeat his wife’s right of dower, but there is also-a presumption that he gave her by his will all that he intended.

In Millikin v. Welliver, 37 Ohio St., 460, it is held that: “If the husband devise his real estate to his wife for life, with remainder to his heirs, and the wife elects to take her dower, or fails to [283]*283make her election, the remainder vests in fee in the heirs, subject to the dower estate of the wife.” This holding is based upon the doctrine of acceleration, but it must be understood as limited to cases in which that doctrine is applicable, otherwise it is too broad. In that case there was no disappointed legatee, but all of the estate went to the remainder-man.- It is well settled, when a widow elects not to take under a will, but to take under the law, her portion under the will will be sequestered to compensate those beneficiaries under the will whose shares are cut down by her election. Pomeroy’s Equity'Jurisprudence, Section 517. It is so held in Jennings v. Jennings, 21 Ohio St., 56. There the testator devised the undivided one-third part of his real estate to his widow for and during her natural life, and the remaining two-thirds thereof to his brothers and sisters in fee simple; the widow elected not to take under the will and then claimed that the testator died intestate as to the fee of the one-third that he had devised to her for life, and that it descended to her by the statutes of descent; she also claimed dower in the remaining two-thirds of the real estate devised to the brothers and sisters, held: “Where, in such case, the widow elects to be endowed of the lands of her husband, the devisees, who are prejudiced by such election, are equitably entitled to compensation out of the rejected provision made for her in the will.” In the opinion the following is quoted with approval from Adams’ Equity: “The effect of election is not to divest the property out of the donee, but to bind him to deal with it as the court shall direct.” See also Pomeroy’s Equity Jur., See[284]*284tion 467.

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Related

Blatchford v. Newberry
99 Ill. 11 (Illinois Supreme Court, 1880)

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Bluebook (online)
78 Ohio St. (N.S.) 276, Counsel Stack Legal Research, https://law.counselstack.com/opinion/holdren-v-holdren-ohio-1908.