In Re the Estate of Santelli

146 A.2d 449, 28 N.J. 331, 1958 N.J. LEXIS 169
CourtSupreme Court of New Jersey
DecidedDecember 1, 1958
StatusPublished
Cited by9 cases

This text of 146 A.2d 449 (In Re the Estate of Santelli) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey 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 Santelli, 146 A.2d 449, 28 N.J. 331, 1958 N.J. LEXIS 169 (N.J. 1958).

Opinion

The opinion of the court was delivered by

Ekancis, J.

This appeal was certified on our motion in order to decide the question of whether the marriage of a man impliedly revokes his antenuptial will. The issue has never before been raised in the courts of this State.

At common law, marriage of a woman ipso facto revoked her will. Upon her assumption of the marital status, the wife’s identity became so merged with that of *333 her husband, and his control over her property so pervasive, that she lost the right to make a will. Consequently, it was considered that because the same capacity is required to revoke a will as to execute one, if the law did not impose revocation as an incident of marriage, the effect would be to endow her will with the quality of irrevocability during coverture. Such immutability was not only contrary to the essential ambulatory nature of a will but inconsistent, as well, with the dominion the husband was entitled to exercise over her person and property. 3 Holdsworth, History of English Law 409, 411, 425, 427 (2d ed. 1909); 1 Jarmam on Wills 148 (3d Amer. ed. 1855); 1 Page on Wills § 516 (3d ed. 1941); Schouler on Wills § 424 (3d ed. 1900); 57 Am. Jur., Wills § 526.

However, the same consequences did not fall upon the antenuptial will of a man. The act of marriage alone did not produce invalidity. Shepherd v. Shepherd, 101 E. R. 29 (1770), note. His will survived until the birth of a child, in which event, in the absence of provision for the child, it was impliedly revoked. Christopher v. Christopher, 2 Dick. 445, 21 E. R. 343 (1771); Marston v. Roe, 8 Ad. & E. 14, 112 E. R. 742 (1838); 6 Cruise, Digest of the Laws of England 101 (1806); 1 Jarman, supra, 148, 149; 1 Page, supra, §§ 510, 515; 57 Am. Jur., supra, § 572. The English courts declared that the combination of marriage and parenthood constituted such a total change in the circumstances of the husband that his previously announced testamentary intent would be deemed altered. After some equivocation on the subject of whether there should be a rebuttable or a conclusive presumption to this effect, the doctrine was rested on the ground that the law imposed on the will at the time of its execution the tacit condition that it would be revoked by implication upon the happening of these specified contingencies. Marston v. Roe, supra.

A number of reasons were advanced for this disparity in treatment, whereby marriage in itself revoked the will of a woman but did not affect that of a man: A wife could take care of herself by antenuptial agreement; the law *334 gave her dower, of which she could not be divested by a testamentary act of her husband; an afterborn child had no such ability to fend for himself and he had no fixed inalienable life interest in his father’s land. And further, it was pointed out that in the event of intestacy, the wife did not qualify as an heir to her husband’s realty. Shepherd v. Shepherd, supra; Brush v. Wilkins, 4 Johns. Ch. Rep. 506, 518 (Ch. N. Y. 1820); 6 Cruise, supra, 105; 1 Jarman, supra, 148; 1 Page, supra, § 510; 57 Am. Jur., supra, §§ 526, 572; 95 C. J. S. Wills, § 291(1).

The doctrine of implied revocation produced many problems to vex the courts. Its applicability where a child was born posthumously was challenged vigorously. The contention was that such a birth could not be said to have affected the testamentary intention of the husband because he might not have been aware of his wife’s pregnancy or could not know if his wife would miscarry, or that the child would be born alive. One aspect of the question was set at rest in Doe v. Lancashire, 5 T. R. 49, 101 E. R. 28 (1792), where the birth of a posthumous child was adjudged to generate the revocation if the husband was aware of the wife’s pregnancy. But as late as 1815, judicial support existed for the proposition that in the absence of such knowledge the will would not be disturbed. Doe v. Barford, 4 M. & S. 10, 105 E. R. 739 (1815). And whether the birth of a child alone after the making of a will would cause revocation was likewise a matter of doubt and uncertainty. Brush v. Willems, supra, 516-519. And see Van Wickle v. Van Wickle, 59 N. J. Eq. 317 (Ch. 1900), wherein Yice Chancellor Pitney declared that at common law the event did not affect the will. Moreover, there were other qualifications on and puzzlements about the rule in action which interfered with the certainty and stability of the law in a field where such qualities were urgently required. 1 Jarman, supra, 152-156; 4 Kent’s Commentaries 522-525 (3d. ed. 1836).

Another facet of the subject should be mentioned for purposes of perspective. A provision was added to the English *335 Statute of Frauds, 29 Car. II, c. 3, § 6, that a devise could not be revoked except by some other will or codicil in writing, or other writing declaring the revocation, or by burning, cancelling, tearing or obliteration; otherwise it should remain in force, “any former law or usage to the contrary notwithstanding.” 8 Statutes at Large 406 (1763). This language stimulated the view that the doctrine of implied revocation had been removed from the law. However, in Christopher v. Christopher and Doe v. Lancashire, supra, the contrary holding was announced. The declaration was made, although not without dissent, that the statute applied only to express revocations and that the instances of implied revocation under discussion remained a living part of the common law. 1 Jarman, supra 150, 151; 1 Page, supra, § 488. Finally, in 1837 Parliament rendered the entire issue academic by enacting a new statute of wills which provided, among other things, that “[e]very will made by a man or woman shall be revoked by his or her marriage” (with an exception not here material) and that “[n]o will shall be revoked by any presumption of an intention on the ground of an alteration in circumstances.” 7 Will. IV & I Vict. Cap. 26, §§ 18, 19; 26 Halsbury’s Statutes of England 1339, 1340 (2d. ed. 1951).

With this historical background, we come into New Jersey to observe the evolution of our law on the subject. Search has revealed no case in the reports prior to 1824 dealing with the effect of the marriage of a man or woman on an antenuptial will.

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146 A.2d 449, 28 N.J. 331, 1958 N.J. LEXIS 169, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-estate-of-santelli-nj-1958.