Jones v. Green

21 Ohio C.C. 96, 11 Ohio Cir. Dec. 548
CourtOhio Circuit Courts
DecidedJanuary 15, 1901
StatusPublished
Cited by3 cases

This text of 21 Ohio C.C. 96 (Jones v. Green) is published on Counsel Stack Legal Research, covering Ohio Circuit Courts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. Green, 21 Ohio C.C. 96, 11 Ohio Cir. Dec. 548 (Ohio Super. Ct. 1901).

Opinion

Summers, J.

The question to be determined is whether the probate court has jurisdiction against the objection of an administrator to adjudicate a claim made against an estate by a claimant other than the administrator,and to order its payment by the administrator, or to order him specifically to perform a contract alleged to have been made by his decedent.

The probate court is a court of delegated powers, having only such jurisdiction as is conferred upon it by the constitution and statutes, and it has not the inherent general jurisdiction of common law and chancery courts. Davis et al. v. Davis, 11 Ohio St., 386, 391; Gilliland v. Adm’rs of Sellers, 2 Ohio St., 223; Jones v. Savings Asso, Co., 18 O. C. C., 189.

The reason is well stated in Woerner’s Am, Law of Admin., section 112,

[98]*98“We'have seen that by the common law the entire scope of jurisdiction over the estates of deceased persons vested in the ecclesiastical, common law and chancery courts. Hence, there being no ecclesiastical courts in America, all such jurisdiction, in so far as it became a part of the juridical system of the states, necessarily vested in the common law and chancery courts, to the extent in which it was not lodged elsewhere by statute. It follows from this, that although in many of the states the constitution establishes or provides for the establishment of courts of probate, yet they take all their powers from the statutes regulating them. From this circumstance arises an important rule to be observed in ascertaining the extent of the power lodged in any one of this class of courts; they can exercise such powers only as are directly conferred upon them by the legislative enactment, or necessary to carry out some power so conferred. Unless a warrant for the exercise of jurisdiction in a particular case can be found in the statute, given either expressly or by implication,the whole proceeding is void; but where jurisdiction is conferred over any subject matter, and it becomes necessary in the adjudication thereof to decide collateral matters over which no jurisdiction has been conferred, the court must, of necessity, decide such collateral issues.”

Article 4, section 8 of the constitution provides that the probate court shall have jurisdiction in probate and testamentary matters, the appointment of administrators and guardians, the settlement of the accounts of executors, administrators and guardians, and such other jurisdiction as may be provided by law.

Section 524, Revised Statutes, provides that the probate court shall have exclusive jurisdiction, among other things, to direct and control the conduct and to settle the accounts of executors and administrators, and to order the distribution of estates. Section 525 confers concurrent jurisdiction in certain specified matters, and section 539 provides that the probate judge shall issue all warrants, attachments, commissions, rules and orders not contrary to law, that are necessary and proper to carry into effect the powers granted to him.

It is not contended that power- to make the order here [99]*99complained of is specifically- given except-by that provision of''section 524 above quoted. The contention is that the administrator acquires title by virtue.of his appointment; that he holds the estate merely'as an agent of the court, and that he must therefore dispose of it as the court directs. That the conduct of an administrator touching the management of an estate, where not prescribed by statute, is by the provision of section 524 subject to the control of the probate court is not doubted, but that such ample power, as is contended, was intended to be vested in the probate court by that provision, is inconsistent with the practice in this state and with other provisions of the statutes. The statutes relating to executors and administrators provide that claims against the estate, other than those owned by the administrator, must be presented for allowance to the administrator; that he may reject them or refer them to arbitration; that rejected claims shall be barred if a suit for the recovery thereof be not commenced within six months; that the administrator shall not be liable to the suit of a creditor excepting upon a rejected claim until after eighteen months from the date of his administration bond; that a creditor whose right of action will not accrue within two yeras after the date of the administration bond may present his claim to the probate court, and that the court, if it appears that the same is justly due, may, with the consent of the creditor and the administrator, order the same paid, or order that the administrator retain sufficient assets to pay it; but. it is expressly provided that the decision of the court shall not be conclusive against the administrator, and that he shall not be compelled to pay the same unless an action thereon be commenced within six months after it becomes due; that upon complaint made to the' probate court or court of common pleas by any person interested that the administrator or any person is suspected of having concealed any of the assets, the court shall cite such person forthwith to appear before it to be examined on oath, and where the complaint ismade tothe probate court and a jury is demanded by either party, the court may forthwith reserve the case to the court of common pleas.

These provisions specifically require a suit or. an action to establish a rejected claim, and necessarily negative any [100]*100intention to vest jurisdiction in the probate court by the provision giving it authority to control the conduct of administrators. A suit or an action must be commenced in a court having general jurisdiction of suits or actions, unless otherwise expréssly provided.

Such jurisdiction is conferred by statute upon the court of common pleas, but not upon the probate court.

“Since the functions of probate courts are limited, in respect of executors and administrators, to the control of the devolution of property upon the death of its owner, it is not their province to adjudicate upon collateral questions. The right or title of the decedent to property claimed by the executor or administrator against third persons, or by third persons against him, as well as claims of third persons against creditors, heirs, legatees, devisees, or distributees, must, if an adjudication becomes necessary, be tried in courts of general jurisdiction, unless such jurisdiction be expressly conferred on probate courts.” Woerner’s Am. Law of Admin., section 151.

Again he says, section 153: “The power to adjudicate upon claims against deceased persons is in most states conferred upon the courts having control over the administration of their estates, either exclusively, or concurrently with other courts; but unless such power is expressly granted, the probate courts cannot exercise it. Thus it is held in Maryland, that authority in the orphan’s court to pass such claims, and authorize and approve their payment, does not include the power to ascertain their validity and amount; hence the orphan’s court has no power, against the protestation of the administrator, to decree the payment of any claim until a court of law shall have definitively pronounced on its validity.

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Cite This Page — Counsel Stack

Bluebook (online)
21 Ohio C.C. 96, 11 Ohio Cir. Dec. 548, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-green-ohiocirct-1901.