In Re Estate of Kozloff

410 A.2d 544, 1980 Me. LEXIS 492
CourtSupreme Judicial Court of Maine
DecidedJanuary 25, 1980
StatusPublished

This text of 410 A.2d 544 (In Re Estate of Kozloff) is published on Counsel Stack Legal Research, covering Supreme Judicial Court of Maine 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 Kozloff, 410 A.2d 544, 1980 Me. LEXIS 492 (Me. 1980).

Opinion

McKUSICK, Chief Justice.

At the time of Nellie Kozloff’s death on July 6,1976, four bank-issued certificates of deposit, worth in total $35,569.25, stood in the names of “Nellie Kozloff or Stanley Kozloff [her son], payable to either or to the survivor.” 1 All of these moneys had belonged to Nellie Kozloff prior to the time she had caused the certificates of deposit to be issued in the joint names of herself and her son. During the probate proceedings, the administrator of Nellie’s estate petitioned the Probate Court (York County) to order Stanley to turn over the funds representing the excess over $5,000 of the certificates of deposit. After hearing, the Probate Court granted the petition and rejected Stanley’s claim that the $5,000 survivor-ship limitation on joint “deposits or accounts” for joint owners who are not husband and wife, as set forth in 9-B M.R. S.A. § 427(4)(B) (1979), 2 is inapplicable to *546 certificates of deposit. The Superior Court, sitting as the Supreme Court of Probate, affirmed the Probate Court’s ruling. Since we also hold that certificates of deposit are “deposits or accounts” within the intendment of section 427(4)(B), we deny Stanley Kozloff’s further appeal to this court.

In construing section 427(4)(B), an examination of its history is particularly helpful. The first enactment on the subject of joint accounts, P.L.1907, ch. 69, § 1 (in the savings bank chapter), provided that money deposited in the names of two or more persons, payable to either, could be paid by the bank “to either of such persons with or without the consent of the other, before or after the death of the other.” As Stanley Kozloff concedes on appeal, the policy underlying that original statute was exclusively the protection of the bank for paying out to the surviving joint owner the funds represented by a joint account.

That 1907 forerunner of section 427(4)(B) did not effect any exception to the firm Maine common law rule that made it extremely difficult to set up a joint tenancy on a bank account or to pass property at death without compliance with the statute of wills. In Staples v. Berry, 110 Me. 32, 85 A. 303 (1912), and Garland, Appellant, 126 Me. 84, 136 A. 459, cert, denied, 274 U.S. 759, 47 S.Ct. 769, 71 L.Ed. 1338 (1927), the survivors of joint bank accounts payable to either of the named depositors claimed unsuccessfully that the accounts created joint tenancies with a right of sur-vivorship. In Staples, the Law Court began with the fundamental proposition that “estates in joint tenancy are not favored in law at the present day and cannot be created in this State without unequivocal and compelling language.” 110 Me. at 36, 85 A. at 304. The court then stated the universal requirements for the creation of a joint tenancy — the four unities of interest, title, time, and possession — which did not contemplate “[a] splitting up of A’s ownership so that B becomes a joint tenant with A.” Id. at 36, 85 A. at 305. Thus, the “naked book entry” was not sufficient to establish a joint tenancy or a gift inter vivos; the creation of a joint account payable to either could reasonably have been intended to be either a convenient arrangement for withdrawals or a testamentary disposition of the balance, which would be void under the statute of wills. Id. at 37, 85 A. at 305. Accord, Garland, Appellant, supra.

In Garland the Law Court in 1927 concluded, “If the creation of a joint interest in bank deposits with the right of survivorship is desirable, the Legislature has power by its fiat to authorize it.” 126 Me. at 98-99, 136 A. at 466. The legislature’s response two years later was “a carefully restricted” law

providing for survivorship in the shares of loan and building associations and comparatively small bank accounts jointly held by a limited class of persons, “even though the intention of all or any one of the parties be in whole, or in part, testamentary, and though a technical joint tenancy be not in law or fact created.”

Strout, Adm’r v. Burgess, 144 Me. 263, 271, 68 A.2d 241, 248 (1949), quoting P.L.1929, ch. 307, § 25(b). For the first time the joint deposit section in the banking laws provided a mechanism for the passage of a property interest at- death. The 1929 law limited survivorship in joint bank accounts to accounts up to $3,000 payable to “persons or to either or the survivor who are husband or wife, parent or child.” P.L.1929, ch. 307, § 25(d). Subsequent amendments have been only in the direction of increasing the amount that may be passed otherwise than by a valid will or joint tenancy, and broadening the degrees of relationship between the decedent and the surviving joint tenant.

*547 In Strout, certain certificates of stock, originally the sole property of Charles T. Burgess, were issued to “Charles T. Burgess or Charles M. Burgess [the decedent’s neph-. ew] as joint tenants with right of survivor-ship and not as tenants in common.” 144 Me. at 264-65, 68 A.2d at 245. The court reaffirmed the common law requirement of the four unities in the creation of joint tenancies; found that the attempted transfer of the various stock certificates from Charles T. to himself and Charles M. lacked the two unities of time and title; and held that intent alone is not sufficient to create rights, such as those inhering in a joint tenancy. Id. at 268-69, 68 A.2d at 247-48. In response to the Strout decision that a conveyance of personal property by one party to himself and another did not create a joint tenancy, the legislature enacted P.L. 1951, ch. 51 [now 33 M.R.S.A. § 901 (1978)], which removed the requirements of the unities of time and title — but only for the transfer of corporate stock. 3 See Milliken v. First National Bank of Pittsfield, Me., 290 A.2d 889, 890-91 (1972).

In the case at bar, as in Staples, Garland, and Strout, the survivor was not entitled to the jointly-held funds as a joint tenant or as the recipient of a valid testamentary gift. The certificates of deposit at issue here had originally been owned by Nellie and William Kozloff, Stanley’s father. When William died in November, 1974, the certificates then owned entirely by Nellie were placed in the names of herself and her son Stanley, “payable to either or to the survivor.” But Nellie could not thereby create a joint tenancy between Stanley and herself, nor could she make the certificates a gift to take effect at her death, as Garland and Staples make clear. The only way Stanley could have a surviv-orship interest to any extent in the certificates that would itself survive the statute of wills or the four unities requirements for a joint tenancy was through the limited exception provided by 9-B M.R.S.A. § 427(4)(B).

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Related

Milliken v. First National Bank of Pittsfield
290 A.2d 889 (Supreme Judicial Court of Maine, 1972)
Staples v. Berry
85 A. 303 (Supreme Judicial Court of Maine, 1912)
Garland
136 A. 459 (Supreme Judicial Court of Maine, 1927)
Strout v. Burgess
68 A.2d 241 (Supreme Judicial Court of Maine, 1949)

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Bluebook (online)
410 A.2d 544, 1980 Me. LEXIS 492, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-kozloff-me-1980.