In re the Estate of Kellogg

129 A. 742, 3 N.J. Misc. 694, 1925 N.J. Misc. LEXIS 8
CourtEssex County Surrogate's Court
DecidedJune 19, 1925
StatusPublished
Cited by1 cases

This text of 129 A. 742 (In re the Estate of Kellogg) is published on Counsel Stack Legal Research, covering Essex County Surrogate's 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 Kellogg, 129 A. 742, 3 N.J. Misc. 694, 1925 N.J. Misc. LEXIS 8 (N.J. Super. Ct. 1925).

Opinion

Iyocher, Advisory Master.

Emily Elvira Wright and Robert Russell Wright, two of the legatees under the last will and testament of Louise A. Kellogg, deceased, file their petition for a decree of distribution, which involves the construction of the will of Louise A. Kellogg for the purpose of determining to whom distribution or payment of the legacies should be made.

Idle pertinent provisions of the will are as follows:

“Second. I give and bequeath unto my sister, Emily Elvira Wright, * * * the sum oí five thousand dollars for use during her life, and, at her death, I give and bequeath the sum, or such parts as shall not be used by my sister, unto my nieces, Emily Louise Wright and Clara Dorothy Wlright.
“I give and bequeath to my brother, Robert Russell Wright, of Denver, Colorado, the use of two thousand dollars during his life, and, at his death, I give and bequeath the said sum, or such part as may remain, unto my nieces, ‘Emily Louise Wright and Clara Dorothy Wright.”

[695]*695Both Emily Elvira Wright and Robert Enssell Wright survived the testatrix.

It is to he observed at the outset that both the legacies in question are alike in the following respects. The bequest to the first taker is expressly for life; no express power of disposition over the corpus is given to the life tenant, and there is a gift over.

On the other hand, the language of the two bequests differ in these respects. The gift to Emily Elvira Wright is of a fund “for use during her life” and a gift over of “the sum, or such part as shall not he used by her;” the bequest to Robert Russell Wright is of “the use of” the fund during his life with a gift over of “the said sum, or such part as may remain.”

As will hereafter be pointed out, the difference appears to be an essential one, and, as a necessary consequence, it becomes necessary to construe the two legacies separately. Eor purposes of convenience the bequest to the brother, Robert Russell Wright, will be first considered.

The first question to be answered is whether Robert is entitled to the fund outright as an absolute gift.

The subject of gifts of property for life or for an indefinite term, with super-added power of disposition over of the fee or principal, expressly granted or implied, has for years constituted one of the most prolific brandies of the construction of wills.

In the first place, it is to lie noted that our courts have drawn a fundamental distinction between those cases in which the gift to the first taker is limited expressly for the term of his life, and those in which it is not so limited. In the leading case of Downey v. Borden, 36 N. J. Law 460, decided by the court of errors and appeals, this rule was enunciated in the following language,:

“The supreme court, in the judgment under review, sustained the claim of an estate in fee in Louise Akins [testator’s widow] in the one-third part of the premises on the rule of construction that a devise of an estate, generally, with a power to dispose of the- same without qualification or limita[696]*696tion, imports such dominion over the property as that an estate in fee is created. The distinction is between a devise expressly for life with a power of disposition annexed and a devise in general terms with such a power annexed. In the former case an estate for li fe only passes, in the latter, a fee. As a rule of construction the principle is entirely settled that where lands are devised, in the first instance, in language indeterminate as to the quantity of the estate from which an estate for life would result by implication, and words adapted to the creation of a power of disposal without restriction as to the mode of execution are added, the construction will be that an estate in fee is given; but where the quantitjr of the estate of the taker is expressly defined to be for life, the super-added words will be construed to be the mere gift of a power of disposition.”

This rule was applied by the court of errors and appeals to bequests of personality in the case of Pratt v. Douglass, 38 N. J. Eq. 516, and in Wooster v. Cooper, 58 N. J. Eq. 682, 684 Chief-Justice Gummere, speaking for that court, used this emphatic language:

“The rule that a devise of an estate generally with a power to dispose of the same absolutely and without limitation imports such dominion over the property that an estate in fee is created and that a devise over is consequently void, has one exception, which is this: That where the testator gives an estate for life only by certain and express words, and annexes to it such a power of disposal, the devisee for life will not take an estate in fee.

“This exception was recognized and enforced by this court in the case of Downey v. Borden, 7 Vr. 460, and again in the case of Pratt v. Douglass, 11 Stew. Eq. 533, and in the latter case it is declared to apply to bequests of personal estate as well as to devises of realty. These cases have definitely settled the law on this subject in New Jersey, and the propriety of the rule laid down in them is not open to discussion.”

I have been unable to find but a single reported case in this state which appears to be contrary to this rule. In Courter v. Howell, 33 N. J. Eq. 80, 81, decided in the court [697]*697of chancery, which held that “when the interest or income of a fund is giren to one for life wit°h a limitation over, and the gift is accompanied with a power to the donee of absolute disposition of the fund during life, the donee will be held entitled to the fund absolutely if he is the equitable owner absolutely.”

This case was, however, distinguished in the case of Reeve v. Beekman, 42 N. J. Eq. 613, 619, on the ground that an express .power of disposal had been given to the legatee, the court’s comment being that “although, in the first instance, the gift of the $3,000 was for life, the testator expressly provided that if the legatee should elect, it might he invested in a house and lot and the conveyance made to her, which, of course, made it absolutely hers, she having so elected.”

From the foregoing it is apparent that there can he no doubt that the courts of this state have unequivocally adopted the rule that a gift of personalty expressly for life, with an absolute power of disposition, gives only a life estate and not an absolute interest.

One point remains to be considered in connection with the question now being discussed, the construction of the word “use.” I have been unable to find any reported case in this state construing this word as applied to a bequest of personalty, but the rule stated in 40 Gyc. 1615, that a gift of the use of property for life gives a life estate, appears to be supported by cases in most of the states and to be questioned by none.

It follows, therefore, that Robert Russell Wright is not entitled to the legacy in question outright as an absolute gift.

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Bluebook (online)
129 A. 742, 3 N.J. Misc. 694, 1925 N.J. Misc. LEXIS 8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-estate-of-kellogg-njsurrctessex-1925.