In re Estate of Wellmeier

26 Ohio Law. Abs. 386, 11 Ohio Op. 45, 1938 Ohio Misc. LEXIS 1222
CourtMontgomery County Probate Court
DecidedFebruary 18, 1938
StatusPublished
Cited by2 cases

This text of 26 Ohio Law. Abs. 386 (In re Estate of Wellmeier) is published on Counsel Stack Legal Research, covering Montgomery 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 Wellmeier, 26 Ohio Law. Abs. 386, 11 Ohio Op. 45, 1938 Ohio Misc. LEXIS 1222 (Ohio Super. Ct. 1938).

Opinion

OPINION

By WISEMAN, J.

This cause comes on to be heard on a demurrer filed to the exceptions filed by John G. Romer, attorney, to the second and final account of the executor and executrix of said estate.

The record in this case shows that on December 23, 1937, the executor and executrix of said estate filed their second and final account, in which no credit was requested in the way of compensation to John G. Romer, attorney at law, who prior to that time had rendered legal services in the administration of said estate. On January 19, 1938, John G. Romer filed exceptions to the second and final account “for the reasons that the said account is not a true and correct statement of the acts and doings of said executor and ex-cutrix of said estate and that said’ account is incomplete because of said omissions. And, further, that this exceptor was engaged as counsel in the settlement of said estate; that he gave advice and rendered services in the settlement of said estate for which said services he has not been paid. Wherefore, said exceptor prays that a hearing will be had of said final account and that the- court make such- order as the facts and law requires.”

The executor and executrix) through other counsel filed a general demurrer to the exceptions on the ground that John G. Romer had no legal authority to file exceptions to the second and final account and that the court was without jurisdiction to hear and determine the matter.

The issue raised in this case is one which vitally concerns every member of the bar and most especially those who represent any person acting in a fiduciary capacity. The lawyers generally fail to realize the nature of their employment by an administrator or executor in the settlement of an estate. The court finds no reported opinion wherein an issue has been raised as in. the case at bar. There are reported opinions bearing upon the nature and characacter of the contract of employment wherein a lawyer renders legal services to a fiduciary and which the court is disposed to follow in determining the issues in the instant case. Since the matter is of such vital importance' to members of the bar, and fiduciaries, in general, the court will review a number of the opinions bearing upon this legal proposition.

The leading case in Ohio is Thomas, Admrx., etc. v Moore, etc., 52 Oh St 200, (1894), the second part of the syllabi stating the legal principle involved is as follows:

“Executors and administrators are personally liable for the services of attorneys employed by them, but their contracts therefor do not bind the estate, although the services are rendered for the benefit of the estate, and are such as the executor or administrator may properly pay for, and receive credit for the expenditure in the settlement of his accounts.”

The court in discussing the personal liability of the administrator, on page 204 say;

“But upon contracts made by the personal representative, though for services and expenses necessary in the due execution of his trust, he is individually liable, for he is without authority to bind the estate by his promise.”

Again on page 205, the court say:

“While it is undoubtedly the right, and in most cases the duty of such representatives to employ counsel to advise and assist them in the performance of their official duties, it cannot be determined that the services rendered by the counsel, or their; value,' constitute a part of the fund in the hands of the representative, however important, and valuable those services may have been in collecting the assets, or resisting unjust claims against them. The law contemplates that the representative will himself-pay the value of such services, and be reimbursed, by receiving credit for [388]*388the amount paid, in the settlement of his accounts.”

Again on page 206, the court quotes from Woerner on Administration, §515, stating the rule to be as follows:

“The rule is, that the administrator can be allowed credit only for counsel fees which he has actually paid, and no more than is leasonable compensation for the services rendered to the estate, no matter what the administrator has actually paid or contracted to pay; and the burden is on him to prove the necessity and value of the services.”

This case has been repeatedly cited with approval by the Supreme Court of Ohio, as well as by courts of inferior jurisdiction. In that case, the Supreme Court held to the proposition that the administrator was personally liable to the a-ttorney for legal services rendered in the settlement of an estate and that until the administrator had paid the attorney he could not ask credit in his account and reimburse himself out of the estate assets. •

In the case of Smith v Rhodes and Wilt, 68 Oh St 500 (1903), the Supreme Court cited with approval the case of Thomas v Moore, and held that the Probate Court may approve, in advance of payment and prior to the time of filing the account, an allowance to the attorney for legal services rendered to the administrator. The court quotes from the opinion on page 508 as follows:

“The Probate Court examined and ap-: proved the expense account in advance of its payment. That court had all the light on the facts, that could have been shed, on an examination of a claim for reimbursement, had the administrator paid the attorney in advance, and taken credit for the same in his account. In this instance the attorney fees were examined and approved in advance of payment, and on final account, ordered paid from the assets, of the estate. The subject had been fully adjudicated and ended. We think the Probate Court had authority to do this.”

The Supreme Court of Ohio in the Smith case has to some extent modified the principle of law which it amiouneed in the Moore case in that the law now gives the authority to the Probate Court to hear and determine the matter as to the allowance of counsel fees for legal services rendered to the administrator in advance of payment. However, in these two cases the administrator brought the question of the allowance of counsel fees before the court. In the case at bar, the executor and executrix have not sought the judgment- of the Probate Court as to the allowance of counsel fees for legal services rendered by John G. Romer to them in the administration of said estate.

Inasmuch as it has been held that the administrator is personally liable for legal services rendered to him while he is acting in a fiduciary capacity, and that the estate assets can only be subjected to the payment of such a claim when the administrator requests that he be allowed a credit in his account, and that he be reimbursed to that extent out of the estate assets, the question arises in the case at bar as to whether or not John G. Romer, counsel for the executor and executrix may in the first instance bring the matter to the attention of the court by filing exceptions to the second and final account of the executor and executrix in which no attempt is made by the executor and executrix to receive a credit cr claim reimbursment.

The Supreme Court of Ohio, in the Moore • case and, also, in the Smith case, held that the contract of employment for legal services in such a situation imposes a personal liability on the administrator.

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Related

In re Brown
129 N.E.2d 497 (Fayette County Probate Court, 1954)
McDonald v. French
32 Ohio Law. Abs. 356 (Ohio Court of Appeals, 1940)

Cite This Page — Counsel Stack

Bluebook (online)
26 Ohio Law. Abs. 386, 11 Ohio Op. 45, 1938 Ohio Misc. LEXIS 1222, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-wellmeier-ohprobctmontgom-1938.