In re the Estate of Crawford

1 Ohio Law Rep. 91, 68 Ohio St. (N.S.) 58
CourtOhio Supreme Court
DecidedMarch 2, 1903
StatusPublished

This text of 1 Ohio Law Rep. 91 (In re the Estate of Crawford) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Estate of Crawford, 1 Ohio Law Rep. 91, 68 Ohio St. (N.S.) 58 (Ohio 1903).

Opinion

The elaborate and very able arguments of counsel, both oral and by brief, invite to an extended discussion of numerous questions germain to the issues covered by the record; but, as we view the case, many of the propositions become unimportant, and the vital questions which are determinative of the rights of the parties in this court may be disposed of in a comparatively limited space.

Briefly stated the claim of the plaintiffs in error, as put by their counsel, is that: Under the terms of item nine of the will the title to all the real estate (wherever .situated) was devised to W. R. Stafford and Clay Crawford as devisees in trust; that upon the pre-bate of the will in Ohio and the acceptance of the trust by Stafford and Crawford, the fee simple title to all real estate in Michigan and elsewhere vested in them as such devisees in trust, and the Probate Court of Lucas County, Ohio, then acquired jurisdiction of such trust and of the trustees; that the probate courts in Michigan have no jurisdiction over testamentary trusts or trustees, chancery having exclusive jurisdiction thereof; that the exceptions which were disallowed covered items amounting to several thousand dollars of moneys received from the s'ales of land, and the products thereof, and expenditures for the cultivation of the land, all which items forih part of the trustees’ accounts over which a court of chancery has jurisdiction. Hence the confirmation of Stafford’s accounts by the Probate Court of Huron County, Michigan, as to these trustee items, was without jurisdiction and void.

That the title to the land is derived from the will and that it vested in Stafford and Crawford as devisees in trust upon their acceptance and qualification as such, and that the Probate Court of Lucas acquired jurisdiction as to matters relating to the trust which should arise out of assets in Ohio, need not be disputed, but the assumption that that court acquired jurisdiction over the conduct of the executors and trustees with respect to lands lying outside the limits of the state of Ohio, does not follow. The claim is directly in conflict with the general rule, held in Vaughan v. Northup, 15 Pet., 1, to be: “Every grant of administration is [108]*108strictly confined in its authority and operation to the limits of the territory of the government which grants it, and does not, de jure, extend to other countries. It can not confer, as a matter of right, any authority to collect assets of the deceased in any other state; and whatever operation is allowed to it beyond the original territory of the grant is a mere matter of courtesy which every nation is at liberty to yield or to withhold according to its own policy and pleasure, with reference to its own institutions, and the interests of its own citizens.” The same doctrine is announced by Justice Storjg in his Conflict of Laws, where, at Section 514, it is stated-: “It is exceedingly clear that the probate grant of letters testamentary or of letters of administration in one country give authority to collect the assets of the testator or intestate only in that country, and do not extend to the collection of assets in foreign countries; for that would be t'o assume an extra-territorial jurisdiction or authority, and to usurp the functions of the foreign local tribunals in that matter. It is no answer to say that the effects of the testator or intestate are assets wherever they are situated, whether at home or abroad, * * * The question is not whether tliej'- are assets or not, but who is clothed with authority to administer them; and this must be decided by the local jurisdiction where they are situated, for the original administration has no extra-territorial operation.” Again, speaking of ancillary administration, the author (Section 513) observes: “Still, however, the new administration is made subservient to the rights of the creditors, legatees and distributees who are resident within the country wherein it is granted; and the residuum is transmissible to the foreign country only when a final account has been settled in a proper tribunal where the new administration is granted, upon the'equitable principles adopted by its own law in the application and distribution of the assets found There.” This is recognized law in Michigan, Reynolds v. McMullen, 55 Mich., 568; McIntire v. Conrad, 93 Mich., 526; in New York, Parsons v. Lyman, 20 N. Y., 103, and seems to be the uniform doctrine of all the courts. It has been regarded as the law of Ohio from early times. In Wills v. Cowper, 2 Ohio, 124, Sherman, J., expresses it thus: “But the' very appointment, ¡as well as the power of an administrator over the estate of a-decedent, emanates from the laws of the country where he receives his appointment. The extent of his authority, and the manner in which it shall be exercised, depend [109]*109upon legislative enactments/ and is confined to the jurisdiction of the country granting the administration. Doe v. McFarland, 9 Cranch, 151. An administrator, as such, can not intermeddle with the effects of his intestate in another state, unless permitted to do so by the laws of that state; otherwise it' would be in the power of one state to regulate the distribution of property situated in another. And the rule is the same whether the administration be general or with the will annexed. In either case the authority of the administrator emanates from the law, and can not extend beyond the jurisdiction of the power conferring the authority; and the will being annexed to the grant of administration, does not change the tenure by which the administrator holds his office.”

It follows from this that the executors could have only such authority over the Michigan lands as is given by the laws of that state, and they provide for the appointment by -the probate court of a special administrator where the validity of a will (as in this case) is contested, and of course such administrator would have to account to the court which appointed him. Dickinson v. Seaver, 44 Mich., 624; 3 Miller’s Compiled Laws of Michigan, paragraphs 9326, 9345, 9346, 9347. It is plain that the executors named in the will could have and did have, as such, no authority over the Michigan property so long as it was controlled, by the special administrator, and it is not of consequence that the administrator was one of the persons named as executor. Iiis authority came from the Probate Court of Huron County, and to that court alone was he required to account. And when the will was probated in Huron county, and letters testamentary issued, it became, by the statute of that state, the duty of the special administrator to turn over to the executor the property in his hands, which was done, and the executor then succeeded to all the powers of the special administrator, and was subjected to the same duty to administer according to the laws of Michigan, and to account to the probate court for his conduct. Same statute, paragraphs 9330, 9345. All these steps seem to have been taken strictly in accordance with the laws of that state, and it is clear, from these statutory provisions, that the state of Michigan has not, by comity or otherwise, extended the right' of an Ohio administrator or executor to administer the trust as to property in Michigan in any other way or manner than subject to the laws of Michigan.

[110]*110It results that the adjudication of the courts of Michigan as to this estate is conclusive upon the plaintiffs in error appearing-in those courts, and settles the controversy here .against them, unless it is shown that such adjudication was without jurisdiction.

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Related

Doe, Lessee of Lewis & Wife v. Mfarland & Others
13 U.S. 151 (Supreme Court, 1815)
Vaughan v. Northup
40 U.S. 1 (Supreme Court, 1841)
Parsons v. . Lyman
20 N.Y. 103 (New York Court of Appeals, 1859)
Dickinson v. Seaver
7 N.W. 182 (Michigan Supreme Court, 1880)
Reynolds v. McMullen
22 N.W. 41 (Michigan Supreme Court, 1885)
McIntire v. Conrad
53 N.W. 829 (Michigan Supreme Court, 1892)

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Bluebook (online)
1 Ohio Law Rep. 91, 68 Ohio St. (N.S.) 58, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-estate-of-crawford-ohio-1903.