Kinard v. Riddlehoover

37 S.C.L. 258
CourtCourt of Appeals of South Carolina
DecidedMay 15, 1832
StatusPublished

This text of 37 S.C.L. 258 (Kinard v. Riddlehoover) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kinard v. Riddlehoover, 37 S.C.L. 258 (S.C. Ct. App. 1832).

Opinion

Curia, per

O’Neall, J.

This case, on account of the novelty and importance of the questions involved in it, has claimed and received from this court more than ordinary attention.

The investigation was one of that kind in wftiich not much aid was to be obtained from authorities. Like most questions arising out of the courts of Ordinary of this State, it is necessary to decide it more upon general principles, than by precedent. The questions made on the [264]*264circuit, and which are stated in the report, have been submitted to the decision of this court, and will be examined and discussed in their order.

1. The rule, as to parties, is said, in some of the books, to be a rule of convenience merely: this, in one sense, is true, but not in every sense. So far as is necessary to the correct administration of justice — a just and valid decision — it may be, as concerns the court, a rule of convenience merely, and if sufficient parties are made for this purpose, all the ends of convenience are answered. But it is also a rule of necessity: for, until the parties to be affected by the judgment of the court are before it, the court has no right to pronounce upon their rights: and any judgment which might be rendered, would be, as against parties not before the court, absolutely void.

To ascertain what parties are necessary to any proceeding, it is always necessary to inquire who are to be affected by the judgment sought to be obtained. Generally, all persons upon whose rights it may immediately operate, must be parties. This rule applies to all courts, whether of superior or inferior jurisdiction. It is conceded, in this case, that all persons who have any interest in the event of the suit are before the court: but it is said that none but the executor or administrator, with the will annexed, can be called on to prove the will in solemn form of law. This is true, when either is in existence. But when no such persons aie in esse, it is impossible to make them parties. Generally, in suits in the courts of law or equity, where the rights of a testator or intestate are in dispute, the executor or administrator must, be a party. But the reason of that rule is, that the legal right to the personal estate of the deceased is in one or the other of these, and, therefore, no judgment to affect it can be pronounced until the legal owner is before the court. The proceeding in the court of ordinary affects none of the rights of property of the deceased ; it is merely a question as to testacy or intestacy. It is preliminary to the character to be given to his legal representative. Where there is no executor appointed or alive, or where the executor refuses to act, it would be not only impossible to make him a party [265]*265to proceedings to obtain or revoke a probate, but the party desiring to defeat the will could not be required to apply for, and obtain, an administration with the will annexed. ,For such a party is not necessary to a just and valid decision upon the issue made, which must be decided before the proper character of the representative of the deceased can be ascertained. If such a party was necessary to be made, one of the parties desiring to set aside the will might be compelled to assume the character, and thus be driven to take the oath required by the law, that the will which he denied to be the will of the deceased was his will. The consequence would be, that he must be estop-ped from contesting the will, and be compelled to swear to what he believes to be untrue. No rule'of law can be so universal in its application, as to produce such unjust and immoral consequences. To avoid them, an exception is necessary, and will be made.

Where a will has once been admitted to probate, and is on record in the Ordinary’s office, a general administration could not be granted. The grant must be according to the character which the proceedings already have given to the estate. An application, therefore, for administration upon the estate of Uriah Wicker, deceased, could not have been granted, generally, as of the goods, chattels and credits of an intestate. Whilst the probate remained un-revoked, it must have been granted cum testamento an-nexo. It could not have brought before the court of Ordinary the question, whether the probate granted should be revoked, so as to conclude the parties in interest. For that proceeding is necessarily upon a general citation and ex parte. In the case before us, the executors named refused to qualify and are now dead : the administratrix, with the will annexed, died a feme covert, and is without any personal representative: her husband’s administrator and heirs are before the court, as the respondents to the allegation filed by the heirs of Uriah Wicker and of his widow and administratrix against the will: these are the only persons in esse who can be affected by the decision of the question made, and it would seem that they are the only parties necessary to be made. The proceeding would [266]*266have been, perhaps, more regular, to have called on the respondents to bring in the letters of administration cum testamento annexo heretofore granted to Mrs. Wicker, and to shew cause against the revocation of the probate, instead of citing them to prove the will in solemn form of law. In the court of Ordinary, there is nothing like technical precision in the proceedings: whatever may be the form pursued there, if it substantially presents the same question which would have been presented in a more formal proceeding, it will be sufficient. We understand that the allegation filed, alleged the supposed will not to be the will of the deceased, and sought to set aside the probate, and to have administration of his goods, chattels and credits, as an intestate. This was, in substance, an applicatian to have the' letters of administration cum testamento annexo called in, and the probate revoked; and to such a proceeding the persons before the court were the proper parties.

2. On the trial of the case I thought, and ruled, that acquiescence by the parties in interest for four years, after the removal of all disabilities, in the probate of a will in common form, would preclude them from requiring it to be proved in solemn form of law. The rule stated in most of the English books appears to be, that at any time within thirty years after probate in common form, the executors may be required to prove a will' in solemn form of law. I had supposed that the English rule to which I have adverted, was still of universal application in the ecclesiastical courts of Great Britain, and that, to sustain the rule which 1 adopted, it was necessary to declare the inapplicability of the English rule to probates in common form in this State, and to adopt a new one for ourselves. On looking, however, more maturely into the question, I am satisfied that, in England, there is no specific rule on the subject. In the cases of Newell vs. Weeks, 2 Phillim. 224, and Hoffman vs. Norris, lb. 230, the parties were held to be concluded from disputing the probate in common form, on the ground of acquiescence. The case of Hoffman vs. Norris not only shews that there is no limitation of time within which applications to have a will proved in solemn [267]*267form of law shall in all cases be made, but. also goes far to sustain the conclusion to which I came on the circuit. The testator, George Hoffman, died in ’95, and his will was proved in common form in the same year.

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Bluebook (online)
37 S.C.L. 258, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kinard-v-riddlehoover-scctapp-1832.