In re Estate of McKenzie

139 N.E.2d 505, 74 Ohio Law. Abs. 106, 1 Ohio Op. 2d 485, 1956 Ohio Misc. LEXIS 314
CourtMeigs County Probate Court
DecidedOctober 18, 1956
DocketNo. 17404
StatusPublished

This text of 139 N.E.2d 505 (In re Estate of McKenzie) is published on Counsel Stack Legal Research, covering Meigs County Probate 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 McKenzie, 139 N.E.2d 505, 74 Ohio Law. Abs. 106, 1 Ohio Op. 2d 485, 1956 Ohio Misc. LEXIS 314 (Ohio Super. Ct. 1956).

Opinion

OPINION

By BACON, J.

Applicant, Laura E. McKenzie, as surviving spouse of James W. McKenzie, deceased, filed an application the pertinent averments reciting that said decedent died intestate September 5, 1956, that all debts and claims against said decedent are fully paid, that decedent left applicant his surviving spouse and David W. McKenzie, of full age, his son, his only heirs at law and next of kin entitled to the next estate of inheritance, that no administration of decedent’s estate is being had or contemplated, that he owned a certain 1956 Ford automobile and certain real estate the value of decedent’s real and personal property not being stated. Further, that applicant, as surviving spouse is entitled to property exempt from administration and widow’s year’s allowance, that applicant and the son agreed that the motor vehicle be transferred to the son. The application asks for such order as may be proper, including the transfer of the 1956 Ford to David W. McKenzie. The son joins in the application.

Applicant does not pretend to be proceeding under §2113.03 R. C., and it would appear, therefore, that decedent’s estate exceeds the sum of $1,000.00. The statute mentioned is directed to cases where the court is satisfied that the assets of an estate are $1,000.00 or less in value.

In order to transfer the motor vehicle aforesaid under Ohio’s Certificate of Title Law from James W. McKenzie, deceased, to David W. McKenzie, particularly under §4505.10 R. C., David W. McKenzie must present to the Clerk of the Common Pleas Court of Meigs County (1) the prior certificate of title to the vehicle (2) his affidavit setting forth the facts entitling him to possession (3) together with a copy of the journal entry, court order or instrument upon which claim of possession and ownership is founded.

It is seen that requirement (3) can only be met by proceedings in the probate court.

In essence, what applicant asks is a partial distribution of decedent’s personal estate without the formal administration the law contemplates—leaving for future order or transfer decedent’s other property, personal and real. But no authority for such order, constitutional, statutory or otherwise, exists.

The Ohio Constitution, Section 8, Article IV, provides:

“The probate court shall have jurisdiction in probate and testamentary matters . . . and such other jurisdiction, in any county or counties, as may be provided by law.”

Implementing this jurisdiction, the Ohio General Assembly has provided, §2101.24 R. C.:

“Except as otherwise provided by law, the probate court has jurisdiction ....

[108]*108(C)to direct and control the conduct and settle the accounts of executors and administrators and order the distribution of estates.

The foregoing appear the only general constitutional and statutory authorities empowering the probate court to act as applicant requests.

Specifically, in the case of real property, the legislature provided that the probate court may issue a certificate of transfer where no administration was had or contemplated. Sec. 2113.61 (D) E. C. No limitation is placed upon the value of the real estate and the attorney general commented, 1936 OAG No. 5193, page 242, that in his opinion a probate judge has permissive power to grant an application for a certificate of transfer under §10509-102 GC its provisions almost identical to §2113.61 (D) E. C., in an estate consisting of real estate, only, exceeding $5,000.00 in value, and where no administration of such estate is had or intended. It will be noted the opinion is confined to “an estate consisting of real estate, only.”

However, the legislature has not seen fit to enact similar provisions for the transfer of titles to motor vehicles, or other personal property, either in the certificate of title law or in the probate code. The reason why such provision is made in the case of real estate and none made in the case of personal property is obvious.

The law of Ohio is that real estate of one dying intestate goes directly to the heirs, and not to the administrator. The heirs possess the legal title full and complete and are the owners of the property in their own right. They are entitled to its possession and control. 17 O. Jur. 2d, Descent & Distribution, Sections 199, 201. In fact, so strong is the heirs right to possession that even where decedent’s lands are required to pay debts, the heirs are entitled to the rents and profits, excluding emblements, until the actual sale of the land by the administrator for the payment of the debts of his intestate. Overturf v. Dugan, 29 Oh St 230.

The law of Ohio is otherwise as to the personalty of a decedent who dies intestate. Such personalty passes not to his heirs at law or next of kin but to his administrator who has legal title. 17 O. Jur. 2d, Descent & Distribution, Section 206. The leading case on this proposition is McBride, Administrator v. Vance, 73 Oh St 258, the syllabi reading:

1. As a general rule administration is a prerequisite to the devolution of the personal estate of a decedent.

2. The personal property of a deceased person does not vest in his heirs but is in abeyance until administration is granted and is then vested in the administrator by relation from the time of death ....

In Rogers v. Metropolitan Life Insurance Co., 24 O. N. P. ns 49, affirmed 16 Oh Ap 283, the superior court of Cincinnati said, “Under the iaw of Ohio administration is indispensable before the heirs can lawfully acquire title to the personal property of a decedent.” Abundant authorities agree. Goudy v. Goudy, Wright 410; Luce v. McDonald, Wright 655; Reed v. Jordan, 12 O. C. C. 161; Rousch v. Hundley et al., 2 O. Dec. Rep. 445. The fact is that so strong is Ohio law to the effect that the personal property of a decedent does not vest in his heirs, but is vested [109]*109in the administrator, reference is made to the case of Davis et al. v. Executors, 25 Oh St 668, syllabus reading:

1. The heirs of an estate cannot, even after settlement by the administrator, and where there are no outstanding debts, maintain an action in their own name to recover possession of assets belonging to the estate.

The issues raised by the instant application have moved the court to examine the Ohio cases involving non-administration of a decedent’s personal property to determine whether some support might be found for granting the application. Study of the cases discloses that the facts upon which they were decided are so utterly removed from the instant proposition, that little support exists.

In the case of Taylor et al. v. Executors, 13 Oh St 288, sole asset of the estates of two sons of a widow, both minors dying unmarried without children, was a small fund then totaling $1,208.27, set up by the will of their grandfather. The widow, their mother, succeeded on a bill in equity in the common pleas court in having the fund paid direct to her without necessity of successive administrations of the minors estates. It will be noted that this case is cited principally for the rule that a beneficiary of a trust may bring a bill in equity to terminate a testamentary trust where circumstances unforeseen by the testator have occurred.

In Catlin et al. v. Huestis, Executor, 5 O. C. D. 23, the testator died in 1887 and the beneficiaries under the will took possession of real and personal assets without an administration.

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Bluebook (online)
139 N.E.2d 505, 74 Ohio Law. Abs. 106, 1 Ohio Op. 2d 485, 1956 Ohio Misc. LEXIS 314, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-mckenzie-ohprobctmeigs-1956.