In re the Last Will & Testament of Ramsdell

16 N.Y. St. Rep. 281
CourtNew York Surrogate's Court
DecidedApril 9, 1888
StatusPublished

This text of 16 N.Y. St. Rep. 281 (In re the Last Will & Testament of Ramsdell) is published on Counsel Stack Legal Research, covering New York 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 Last Will & Testament of Ramsdell, 16 N.Y. St. Rep. 281 (N.Y. Super. Ct. 1888).

Opinion

Addington, S.

This is a motion to dismiss the proceedings of the proponents, for failure to prove the mental competency of the alleged testatrix.

The motion was first made at the close of proponent’s case, and was denied off-hand, without examination of the testimony given on the hearing, and with the expectation that the production of witnesses, on both sides, would follow; but [282]*282the fact that counsel appeared between the time of the informal argument and the day fixed for taking testimony, and requested that further arguments be heard, and that briefs might be submitted, leads me to. infer that the parties wish the whole matter disposed of by the decision of this motion.

. The motion rests chiefly upon technical grounds, and relates to forms of procedure rather than to the real merits of the issue, formed 1by the pleadings herein, which issue is the sanity of the decedent. No witness, from the city in which Mrs. Eamsdell had so long lived, and in which she had successfully transacted the business of her large estate, has been called to give evidence as to the competency, or incompetency, of the deceased, to make a will. The parties to this contest have preferred to subordinate the principal question to a controversy over the order of proofs and methods of procedure; and the only person examined in the proceeding is the survivor of two attesting witnesses, who, at the time of the execution of the will, was a stranger to the decedent, and entirely unacquainted with her habits, character, feelings and capabilities.

It is needless to say that such testimony does not furnish a satisfactory basis for a fair and an intelligent judgment on the main question in issue, and that, in deciding this motion, I do not pass upon that question, except as it is incidentally involved in the technical issue raised by this motion.

The proponents’ position on the motion is that they are only required, in the first instance, to prove the formal execution of the will, and that such proof being made, a legal presumption of the sanity of the testator then arises, on which proponents may safely rest until the contestants have given evidence tending to show the insanity of such testator; to which evidence the proponents may then oppose such evidence as they may have in support of decedent’s soundness of mind.

The contestants insist that this position is incorrect, and that the proponents, before resting, must prove, prima facie, not only the formal execution of the will, but also the decedent’s soundness of mind, and freedom from restraint; and that the necessity for furnishing such proof is the stronger in the present case from the fact that the only witness sworn testifies that, in his opinion, the decedent was of unsound mind at the time of executing the alleged will.

This precise point has seldom been discussed in the reported decisions of this state. The usual practice in will contests, involving the sanity of the testator, in our surrogate’s courts, is, for the proponent to prove the formal execution of the will, and to show, prima facie, by the attesting witnesses, the decedent’s age, mental competency and freedom from restraint. The contestant then offers his evidence in.support of his allegations of unsoundness of mind, [283]*283and the proponent closes with testimony in reply, and in support oi the allegations, which he is bound to maintain.

On the whole issue, made as just stated, the courts of this state have frequently declared that the burden of proving a decedent’s unsoundness of mind is on him who asserts the existence of that unnatural condition. This doctrine is formulated in Delafield v. Parish, 25 N. Y., 97, and has been often reiterated by all of our courts.

It must be observed, however, that this is a very different question from the one here presented; for the contestant has as yet offered no testimony, and maintains that the proponents must fail for the lack of proof of a material fact.

This distinction is clearly drawn, in the opinion of the general term of the third department, in Harper v. Harper, 1 Thompson and Cook, 355, m which the court says:

“ It is the established law of this state that the legal presumption, to begin with, is that every man is compos mentis, and the burden of proof that he is non compos mentis, rests on the party who alleges that unnatural condition of mind existing in the testator. But it is also the rule that, in the first instance, the party propounding the will must prove the mental capacity of the testator.”

In Delafield v. Parish, 25 N. Y., 34, Judge Davies also says:

“ The party propounding the will is bound to prove to the satisfaction of the court that the paper in question does declare the will of the deceased, and that the supposed testator was, at the time of making and publishing the document, propounded as' his will, of sound and disposing mind and memory.”

In Kingsley v. Blanchard, (66 Barb., 317, 322), a case in which only the subscribing witnesses to the will were sworn, and_ where neither of them stated whether or not the testartrix was of sound mind, after some discussion of the testimony as to the execution of the will, and a quotation of the provisions of the Revised Statutes regulating the probate of wills, the general term say:

“ The question then is, whether the testatrix is shown to have been a person of sound mind within the meaning of these terms when applied to testamentary dispositions of property. This fact must be proved; and the burden of its proof rests on the party propounding the will.” * * * .

“If the legislature had intended (by the provisions of the statutes above mentioned), that the surrogate might be satisfied with presumptive proof, it would never have been guilty of the folly of requiring a fact to be proved which the law presumed to exist.”

Again in Miller v. White (5 Redfield, 321), it is said:

“The burden o£_ proving unsoundness of mind is on the contestant, but it is expected of the party offering a will for [284]*284probate that he "will examine the subscribing witnesses as to the condition of the testator’s mind.”

In the Matter of the Will of Cottrell (95 N. Y., 336), the court of appeals say: “ The proponent has the affirmative of the issue, and if he fails to convince the trial court by satisfactory evidence that each and every condition required to make a good execution of a will has been complied with, he will necessarily fail in establishing such will.”

In the only recent work on surrogate’s Practice in this state, Redfield’s Law and Practice of Surrogate’s Courts, (3ded.), 216, the matter is put as follows: “On the question of probate, the orderly and proper course for the introduction of evidence is, first, to prove the requisite formalities attending the execution, publication and attestation of the will, and then show that the testator was at the time, of the proper age and mental soundness, and was not unduly influenced in the testamentary act. ”

The necessity for observing this order of proof is now emphasized by the provisions of the Code of Civil Procedure, § 2622 and 2623. As to the former, Surrogate Rollins says in Cooper v. Benedict (3 Demarest, 136), that it has lent a new sanction to the doctrine enunciated in Delafield v. Parish

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Kingsley v. Blanchard
66 Barb. 317 (New York Supreme Court, 1860)
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19 Mich. 482 (Michigan Supreme Court, 1870)

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Bluebook (online)
16 N.Y. St. Rep. 281, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-last-will-testament-of-ramsdell-nysurct-1888.