In re Estate of Block

190 A. 315, 15 N.J. Misc. 233, 1937 N.J. Misc. LEXIS 7
CourtEssex County Surrogate's Court
DecidedFebruary 24, 1937
StatusPublished
Cited by1 cases

This text of 190 A. 315 (In re Estate of Block) is published on Counsel Stack Legal Research, covering Essex County Surrogate's Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Estate of Block, 190 A. 315, 15 N.J. Misc. 233, 1937 N.J. Misc. LEXIS 7 (N.J. Super. Ct. 1937).

Opinion

Hartstorne, C. P. J.

We have here for consideration the “somewhat difficult question of the effect of the cancellation of a later will upon an earlier one.” Re Diament’s Estate, 88 N. J. Eq. 552; 103 Atl. Rep. 199. Unfortunately the Court of Errors and Appeals did not find it necessary to answer such question in the above ease, and in the two other leading New Jersey cases on the subject (Randall v. Beatty, 31 N. J. Eq. 643; Re Moore’s Will, 72 Id. 371; 65 Atl. Rep. 447) it is far from clear whether the courts apply the rule originally adopted by the English courts of common law or the differing one adopted by the English ecclesiastical courts, for both are referred to. Turning from the New Jersey courts to outside jurisdictions we find “confusion worse confounded.” Eor in England at first the common law courts adopted one rule, the ecclesiastical courts another, and later upon the enactment of the [234]*234Statute of Victoria as to wills, a third was fixed upon. Statute of Victoria, 1837, 7 Wm. IV and 1 Vic., ch. 26, § 22. Turning to this country we find that one group of courts has followed the English common law rule (Connecticut, Illinois, Horth Carolina, Ehode Island, Vermont), another group the rule of the English ecclesiastical courts (Iowa, Maryland, Massachusetts, Michigan, Minnesota, New Hampshire, Pennsylvania), a third the English rule adopted under the Statute of Victoria (California, Indiana, Kansas, Missouri, New York, Ohio), while two other groups diverge still further. 1 Page on Wills (2d ed.), Iff 442 to 448. To understand more clearly the difficulties which have thus caused our courts to differ so 'variously, the typical facts, appearing in this case, should be borne in mind.

Philip Block executed his first will in 1922, leaving same with his then attorney, Benjamin Yawitz, to keep for him. This will is now produced by the attorney for probate. In 1928 testator returned to his attorney and executed a second will, telling the latter to keep both because “I want to see how the children are going to act towards me.” There is a dispute as to this, a son claiming that at or about the time of the execution of the 1928 will the 1922 will was thrown by Yawitz into the scrap basket in testator’s presence. But not only do we have the attorney’s denial of this, but that of several disinterested witnesses, who say no such thing occurred and that the son was not present at the execution of the 1928 will. Later the decedent obtained his 1928 will from his lawyer and took it home, where he kept it till a few months before his death, in his safe. To this safe only he and this son had access. The 1928 will was not found after decedent’s death, and there being no motive fox the son’s destroying it, and no testimony even hinting same, it is well established that the 1928 will must be deemed to have been destroyed by testator animo revocandi. Re Calef, 109 N. J. Eq. 181; 156 Atl. Rep. 475; affirmed, 111 N. J. Eq. 355; 162 Atl. Rep. 579; Re Willett’s Estate, 46 Atl. Rep. (N. J.) 519.

So far the situation creates small difficulty. The real difficulty arises due to the fact that the 1928 will, a copy of [235]*235■which exists, contained a clause expressly revoking former wills. The question thus is, whether the 1922 will now produced by decedent’s attorney, Mr. Yawitz, is in effect, despite the execution of the later will containing the revocation clause, and the latter’s revocation subsequently.

According to the rule of the English common law courts, as stated in Randall v. Beatty, supra, “where one will is revoked by another, the revocation is testamentary, and the revocation of the latter will revives the former.” According to the rule of the English ecclesiastical courts, apparently applied in Re Moore's Will, supra, the revocatory clause included in the later wilL takes effect at once, on execution, to revoke the earlier will, it being a question of testator’s intention as to whether or not the earlier will is revived by the subsequent destruction of the later will. Both these differing viewpoints are well set forth in Whitehill v. Halbing, 98 Conn. 21; 118 Atl. Rep. 454, with their supporting and conflicting authorities throughout the United States, exhaustively, not to say exhaustingly, discussed, if we may judge from the language in the dissenting opinion of the Supreme Court of Errors of Connecticut, where the Chief Justice takes pointed issue with his colleagues. The third major rule is that adopted by the English courts subsequent to the enactment of the Statute of Yictoria, supra, in 1837. Major v. Williams, 3 Curt. Roc. 432; 1 Page on Wills, § 446. This rule, which has in turn been followed by another series of American state courts, is to the effect that the execution of a later will, with a revocatory clause, revokes the first, but that, on the revocation of the later will, the earlier will is not revived unless re-executed and republished.

To guide our footsteps in this confusing situation the following landmarks stand out:

1. The devolution of property at death is a matter of such importance both to the individuals involved and to the public, and so subject to possible fraud when the lips of the previous owner have been sealed by death, that the public, through the legislature, has fixed definite rules as to how property may so pass.

[236]*2362. The intention of the testator is important, but in view of such danger of fraud, the evidence of such intention must be definite, and ofttimes of statutory character.

3. Wills are ambulatory in character, i. e., speak only from date of death.

4. The law abhors intestacy.

Before the establishment of the above rules by the courts and their general recognition as landmarks, a duly executed will could be revoked by mere word of mouth. This was soon found so uncertain and subject to fraud that provisions were inserted in the statute of frauds as early as 1687 to prevent such oral revocation of a will. .29 Gar. II, ch. 3, §■§ 6, 22. These provisions of the English statute of frauds have been re-enacted substantially verbatim in the New Jersey statute of wills and now constitute sections 2 and 25 of such statute, as follows:

“Sec. 2: That no devise or bequest in writing, of any lands, tenements, hereditaments or other estates whatsoever in this state, or of any estate pur auter vie, or any clause thereof, shall be revocable, otherwise than by some other will or codicil in writing, or other writing declaring the same, or by burning, canceling, tearing or obliterating the same by the testator himself or in his presence, and by his direction and consent; but all devises and bequests of any lands, tenements, hereditaments, or other estates whatsoever in this state, or of any estate pur auter vie, shall remain and continue in force until the same be burnt, canceled, torn or obliterated by the testator or by his directions in manner aforesaid, or unless the same be revoked or altered by some other will or codicil in writing, or other writing of the devisor signed in the presence of three or more subscribing witnesses declaring such revocation or alteration.
“Sec.

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In re Estate of Davis
15 A.2d 895 (Bergen County Surrogate's Court, 1940)

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Bluebook (online)
190 A. 315, 15 N.J. Misc. 233, 1937 N.J. Misc. LEXIS 7, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-block-njsurrctessex-1937.