In re the Estate of Walters

38 V.I. 14, 1997 WL 889531, 1997 V.I. LEXIS 25
CourtSupreme Court of The Virgin Islands
DecidedApril 11, 1997
DocketProbate No. 104/94
StatusPublished
Cited by1 cases

This text of 38 V.I. 14 (In re the Estate of Walters) is published on Counsel Stack Legal Research, covering Supreme Court of The Virgin Islands 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 Walters, 38 V.I. 14, 1997 WL 889531, 1997 V.I. LEXIS 25 (virginislands 1997).

Opinion

STEELE, Judge

MEMORANDUM OPINION

Vincent and Rodeny Walters petition this Court to invalidate their father's will and for distribution of his estate under the Virgin Islands intestacy laws. Petitioners argue that either the Virgin Islands Pretermitted Child Statute, 15 V.I.C. Sec. 18, or the Uniform Simultaneous Death Act, 15 V.I.C. Sec. 88, invalidates testator's will, thus subjecting testator's estate to intestacy. The issue here is twofold: First, whether testator's will is valid; and second, whether the aforementioned Virgin Islands statutes have any revocatory or interpretive effect upon testator's will.

FACTS

The facts of this case are simple, and substantially undisputed.

Testator, Benjamin Ezekiel Walters and Iona V. Walters, his wife, met their deaths in a tragic house fire, on June 25,1994. Apparently, the couple died of asphyxia and extensive bodily burns in the second, third, and fourth degree. However, Mrs. Walters' body also exhibited multiple deep lacerations of the head, skull fractures, brain damage and hemorrhage; ostensibly, as a result of physical blows inflicted by testator. Testator's body displayed no similar physical mutilations other than those associated with a fire death. [16]*16The couple's death certificates point only to simultaneous demise, and contrary evidence of survivorship by either of the couple was never provided by the litigants.

Prior to his death, some nine years ago on April 22,1986, testator executed a will devising his entire estate to his wife, and appointing her executor. Testator, mindful of the possibility that his wife may predecease him, named his step-son, Ocian Fraser, the natural son of Mrs. Walters, as an alternative devisee. The will also named one Vincent Pinney as the replacement executor. Testator's will provides in relevant portions:

Article 2:1 hereby give and devise all my estate, both real and personal of which I may possess upon my death, including all property acquired by me or to which I may become entitled after the execution of this will, to my wife, Iona V. Walters, of Plot No. 34A Hannah's Rest, Frederiksted, St. Croix, U.S. Virgin Islands.
Article 3: In the event that the above named beneficiary [wife Iona V. Walters] should predecease me, her share shall descend to her son, Ocian Fraser. . . .

On October 28, 1994, Mr. Ocian Fraser filed petition to admit testator's will to probate, naming Mr. Pinney as executor. The petition listed few assets in the estate: a $134.00 savings account, and a parcel of land upon which the marital homestead is built. The land is assessed at $8,460.00 for tax purposes, and the marital homestead is assessed at $23,389. However, because the homestead was destroyed in the same fire that ended the couple's life, the actual value remains unknown, as no new valuations were submitted to this Court indicating a new value reflective of the property's destroyed condition.

As the contingent beneficiary, under article 3 of testator's will, Fraser stood to inherit the entire estate. Testator's two natural children, hereinafter "petitioners," objected to Fraser's petition to admit testator's will to probate, and to appoint Vincent Penny as executor. Petitioners impugn the validity of testator's will on two grounds. First, petitioners argue that testator's failure to expressly disinherit petitioners from the will rendered the will invalid under 15 V.I.C. Sec. 18. Second, petitioners argue that the Uniform [17]*17Simultaneous Death Act invalidates testator's will. Finally, petitioners implicitly raise undue influence, and possibly duress, by the deceased beneficiary as further grounds for invalidating the will. By challenging the validity of the will, petitioners seek to place testator's estate under the Virgin Islands intestacy laws, which would allow petitioners a share of the estate. Naturally, Mr. Fraser objected, reaffirming the validity of testator's will and his entitlement as a contingent beneficiary to testator's entire estate.

DISCUSSION

The first issue presented to this court is whether testator's omission of his natural children, without specific testamentary language to that effect, invalidates testator's otherwise valid will, under 15 V.I.C. Sec. 18. The second issue is whether the simultaneous demise of the beneficiary spouse and the testator effectuates a different disposition of testator's estate than that of testator's will, under the Uniform Simultaneous Death Act, 15 V.I.C. Sec. 88. We first address the issue of whether the will is valid. We then examine whether 15 V.I.C. Sec. 88 provides for any revocative or interpretive influence upon testator's will.

A. The Validity of Testator’s Will

Under the Virgin Islands probate code, a will is valid if it meets the testamentary formalities set out in 15 V.I.C. § 13. Failure to abide by these formalities renders a will invalid. See Estate of Georg, 7 V.I. 298, 298 F. Supp. 741 (D.C.V.I. 1969). Notwithstanding the foregoing codified testamentary formalities, a will may be entirely revoked in two ways: Revocation by Physical Act and Revocation by a Subsequent Writing.1 15 V.I.C. § 26. Aside from [18]*18complete revocation, the Virgin Islands probate code also provides for the partial revocation of a will, under limited circumstances, for the limited purpose of re-interpreting such wills for the benefit of a perceived public goal. One such type of partial revocation occurs under the Pretermitted Child Statute, 15 V.LC. § 18. The purpose behind such statute is to protect children inadvertently omitted from a will executed prior to their birth. Further, the spirit of this statute comprehends the prevention of unintentional disinheritance of children. Mindful of the express language and utility of 15 V.I.C. Sec. 18, we turn our attention to its application, if any, upon the instant case.

1. The Pretermitted Child Statute

In the Virgin Islands, the Pretermitted Child Statute is codified under 15 V.I.C. Sec. 18, which provides in part: ¡

(a)' Whenever a testator shall have a child horn after the making of a last will,. . . and shall die leaving such child, . . ., unprovided for by any settlement, . . ., nor in any way mentioned in such will, every such child shall succeed to the same portion of such parent's "real and personal estate, as would have descended or been distributed to such child, if such parent had died intestate, and shall be entitled to recover the same portion from the devises and legatees, in proportion to and out of the parts devised and bequeathed to them by such will.

15 V.I.C. Sec. 18(a) (emphasis supplied).

The predecessor statute to 15 VI.C. Sec. 18 was Title II, chapter 10 Sec. 7 of the 1921 Code, which statutory language provides in pertinent part:

"If any person make his last will and die, leaving a child or children. . . not named or provied for in such will, although born after the making of such will or the death of the testator, every such testator, so far as shall regard such child orchildren, . . . not provided for, shall be deemed to die intestate and such child or children, . . . shall be entitled to such proportion of the estate of the [19]*19testator, real and personal, as if he had died intestate,

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In re the Estate of Savain
39 V.I. 91 (Supreme Court of The Virgin Islands, 1998)

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Bluebook (online)
38 V.I. 14, 1997 WL 889531, 1997 V.I. LEXIS 25, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-estate-of-walters-virginislands-1997.