In re Estate of Thatcher

30 Ohio N.P. (n.s.) 515, 1933 Ohio Misc. LEXIS 1781
CourtOhio Probate Court of Franklin County
DecidedJuly 5, 1933
StatusPublished

This text of 30 Ohio N.P. (n.s.) 515 (In re Estate of Thatcher) is published on Counsel Stack Legal Research, covering Ohio Probate Court of Franklin County 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 Thatcher, 30 Ohio N.P. (n.s.) 515, 1933 Ohio Misc. LEXIS 1781 (Ohio Super. Ct. 1933).

Opinion

McClelland, J.

Harvey N: Pinnick as the administrator of both of the above estates has filed with this court a petition in each case, for a determination of the heirs of both decedents. Since the question involved is the same in both cases, these petitions were heard at the same time.

The petitions state that Edward W. Thatcher died on April 13, 1933, and that Jessie May Thatcher, who was the wife of Edward W. Thatcher, died on April 16, 1933, but within three days after the death of her husband; that both decedents died leaving no children and no father or mother; that Jessie May Thatcher left three brothers, Edward,William and Harley Scarrett, and that Edward W. Thatcher left no brothers or sisters, but left a niece, Nellie McCann. The testimony taken at the hearing substantiates the above allegations, except that the niece of Edward W. Thatcher is named Dorothy McCann and not Nellie McCann. These facts however are not disputed. .

The court is asked in both cases to determine who are entitled to inherit; the question being whether or not Jessie [516]*516May Thatcher is entitled to inherit from her husband, Edward W. Thatcher, and vice versa.

The question arises upon the construction of Section 10503-18 of the Probate Code, which became effective January 1, 1932. This is the first time that this question has been presented to this court, and counsel for both sides state that they have been unable to find any decisions of any other courts in Ohio involving this question.

The statute under which we are asked to determine this question is Section 10503-18, General Code, which reads as follows:

“Section 10503-18, General Code — Presumption of Order of Death. When there is no evidence of the order in which the death of the two or more persons occurred, no one of such persons shall be presumed to have died first, and the estate of each shall pass and descend as though he had survived the other or others. When the surviving spouse or other heir at law or legatee dies within three days after the date of death of the decedent, or within thirty days after the date of death of such decedent if such death resulted from a common accident, the estate of such first decedent shall pass and descend as though he had survived such heir-at-law or legatee. The provisions of this section shall prevail over the right of election of a surviving spouse.”

In view of the fact that we have not been advised of any other case in Ohio involving the construction of Section 10503-18, General Code, the court will consider briefly some of the numerous reasons set forth by counsel for the heirs of Jessie May Thatcher why the statute should not apply to these cases.

Counsel argues that this statute “is special and was enacted for a definite and specific purpose,” the purpose being stated as he says in the first clause of the statute as follows:

“When there is no evidence of the order in which the death of two or more persons occurred,”

and he quotes Babjak v. Ivanick, et al., 27 N. P. (N. S.) which is a case involving the construction of the half and half statute, now Section 10503-5, General Code. We need only state that this is a special purpose statute but that the statute covers three distinct situations, and that the [517]*517second sentence of the statute is not predicated upon the first clause in the statute. The first clause does not embody the reason for the whole statute, but merely states a situation which the sentence was enacted to cover.

It is quite clear that the first sentence of the statute deals with a situation where there is no evidence, of the order in which the deaths of two or more person occurred. Such a situation may be readily imagined; take for instance an aer'oplane accident in which several lives are lost and all the passengers are found dead when the plane is first discovered; there is no evidence of the order in which the deaths occurred. The deaths may have been instantaneous, some may have lingered on for days, and some may have survived for more than a month before they were discovered dead. In such a case, where there is no evidence of the order in which the deaths occurred, no one of such persons shall be presumed to have died first. The first sentence of the statute applies to such a case, and it must be observed that it applies to all persons and includes husband and wife, heirs-at-law or legatees, or any persons entitled by law or will to a share in the estate of the other decedent.

This part of the statute serves the purpose of doing away with a lot of speculation in cases of that kind, as to which person died first. s

Counsel for the brothers of Jessie May Thatcher also claims that the statute applies only in cases where the deaths resulted from a common accident. The wording of the statute is clear, and makes a distinction between deaths occurring within three days, (which may have resulted from any cause) or within thirty days, where the deaths resulted from a common accident. In other words, the statute lengthens the time of its operation to thirty days where the deaths are the result of a common accident, and limits it to three days when the deaths are not the result of a common accident.’

Counsel for the brothers of Jessie May Thatcher lays much stress upon the fact that the statute provides that,

“the estate of such first decedent shall pass and descend as though he had survived such heir at law or legatee,”

and that the term “surviving spouse” is omitted in this part of the statute. His claim is that the term “surviving [518]*518spouse” is not included in the term “heir at law” used in the statute.

Upon this point we quote the Supreme Court case of Weston v. Weston, 38 O. S. 473, which involved the construction of a will wherein the term “heirs-at-law” was used, and held that the term included the widow of the decedent. The syllabus of that case reads as follows:

“A testator, having executed his will giving, in trust for the benefit of his sole and only child, property consisting of non-ancestral real estate and personal property, and directing that ‘in case my said child should die without issue her surviving, then all and singular the property so devised shall pass to and vest in my heirs-at-law,’ died leaving surviving him his said child, and also his wife, a brother and two sisters who survived the child. Held: That upon the death of the child without issue, the widow of the testator succeeded to the property, under the will, as heir-at-law of the testator.”

The following excerpts are copied from the opinion of the court:

“In support of this contention it is claimed that a husband or wife relict, who succeeds to the estate of the deceased husband or wife, cannot, in a legal sense, be called an HEIR: and Gauch v. St. Louis M. L. Ins. Co., 88 Ill. 251, is relied on as authority. We think the case cited is directly against the claim. The point there decided is, that one taking a dower estate does not succeed to it as an heir; but Rawson v. Rawson, 52 Ill., 62, and Richards v. Miller, 62 Ill. 417, are approved, which hold that a wife or husband relict who takes under the law of descent takes as HEIR. And such we think is the legal meaning of the word. Brower v. Hunt, 18 Ohio St., 311.

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Related

Foraker, Exr. v. Kocks, Admx.
180 N.E. 743 (Ohio Court of Appeals, 1931)
Rawson v. Rawson
52 Ill. 62 (Illinois Supreme Court, 1869)
Richards v. Miller
62 Ill. 417 (Illinois Supreme Court, 1872)
Gauch v. St. Louis Mutual Life Insurance
88 Ill. 251 (Illinois Supreme Court, 1878)

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Bluebook (online)
30 Ohio N.P. (n.s.) 515, 1933 Ohio Misc. LEXIS 1781, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-thatcher-ohprobctfrankli-1933.