Landfear v. Scharkofsky

32 Ohio N.P. (n.s.) 217, 1934 Ohio Misc. LEXIS 1454
CourtCuyahoga County Probate Court
DecidedMay 25, 1934
StatusPublished

This text of 32 Ohio N.P. (n.s.) 217 (Landfear v. Scharkofsky) is published on Counsel Stack Legal Research, covering Cuyahoga County Probate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Landfear v. Scharkofsky, 32 Ohio N.P. (n.s.) 217, 1934 Ohio Misc. LEXIS 1454 (Ohio Super. Ct. 1934).

Opinion

Brewer, J.

On October 17, 1930, Rudolph G. Scharkofsky executed his last will and testament and died on January 29, 1932. His will was admitted to probate in this court on March 22, 1932. He left surviving him his widow and three children, two adults, who are the issue of a former marriage and who have raised the question involved.

By the terms of Item Two of his will, he devised certain real estate to his widow for and during her life and the [218]*218remainder to his children. Certain other real estate was devised to his wife subject to certain bequests.

By the terms of Item Seven, the residue of his estate was given, devised and bequeathed to his widow.

Item Eight of his will reads as follows:

“Item VIII. The provisions herein before made for my wife Anna Seharkofsky are intended to be in lieu of her dower interest in my real estate and distributive share of my personal property as well as her claim to a year’s support and any and all other rights, interest or claims she might otherwise have in or against my estate. And said provisions are conditioned upon her formal relinquishment of such rights by election or otherwise. In case my said wife shall, for any reason, elect not to take under my will then the provisions hereinbefore made for her, subject to her claims at íaw upon the same shall pass to and vest in my children in equal parts.,”

The surviving spouse, Anna Seharkofsky, was served on March 14, 1933, with a citation in accordance with Section 10504-55, General Code, requiring her to make her election to take under the will or the law within one month from the date of said service. She did not make an election. The administrator de bonis non, with the will annexed filed a petition in this case for the construction of decedent’s will and for a declaratory judgment. Pleadings have been filed and all necessary parties are properly before the court.

The question at issue in this case arises by reason of Section 10509-54, General Code, which provides, so far as pertinent here, that the widow shall have twenty per centum (20%) of the decedent’s gross estate limited by a maximum of $2500.00. The provisions of said section are not limited to intestate cases.

The question is whether a widow, who has failed to make her election within the one month limited by law, after service of citation to make her election and who, therefore, is bound by the terms of the will, is entitled to receive in addition to the provisions for her in the will, the sums provided by Section 10509-54, General Code. There is in this case no language in the will expressly referring to the exemptions provided by this section. However, at the time the testator made his will, he used language designed to [219]*219bar the widow of every right at law she might then have. Section 10954, General Code, was then in force. That section provided similar exemptions to those allowed by Section 10509-54, General Code. The latter section, however, substantially increased those rights. The change went into effect just twenty-nine days before the testator died.

It is admitted in the case at bar that the intention of the testator is clearly expressed and that he intended that if his widow should take the property provided for her in his will, that she might have only that property. The court must then determine two things, first, has the testator the right under the law to require the surviving spouse to elect between the will and the exemptions provided by Section 10509-54, General Code, and, if he has, was the language used in this will, sufficient ?

Section 10509-54, General Code, went into effect on January 1, 1932, as a part of the so-called New Probate Code, by which Section 8606, General Code, providing for vested dower, was repealed. Manifestly, the increase in the amount of the exemptions provided for the surviving spouse in Section 10509-54, General Code, was to offset, at least in part, that which was taken away.

Before the New Probate Code, Section 10569, General Code, controlled the right of the widow as between the will and vested dower. It read:

“Dower and Gift. — No widow or widower shall be entitled both to dower and the provisions of the will in her or his favor, unless it plainly shows that such provision was intended to be in addition to dower and a distributive share of the estate.”

It will be noted that no express provision was required in a will to bar dower and that, in fact, for the surviving spouse to take both dower and the provisions in the will, there had to be a provision in the will to that effect. Section 10572, General Code, also formerly had some bearing on this kind of case. It read:

. “Election to take under' the will; effect of. — If the widow or widower elects to take under-the will, she or he shall be thereby barred of dower and such share of personalty, and shall take under the will alone, unless as provided in Section 10569.. But an election to take under the will does not bar the right to remain in the mansion of the deceased [220]*220consort, or the widow to receive one year’s allowance for the support of herself and children, as provided by law, unless the will expressly otherwise directs.”

Both Section 10569 and Section 10572, General Code, as well as the dower statute, Section -8606, General Code, were repealed by the New Probate Code. Section 10504-61, General Code, now provides what the effect of an election under the will shall be. It reads:

“Election to take under the will; effect. — If the surviving spouse elects to take under the will, such spouse shall be thereby barred of all right to an intestate share of the estate, and shall take under the will alone, unless it plainly appears from the will that the provision therein for the spouse was intended to be in addition to an intestate share. But an election to take under the will does not bar the right to remain in the mansion of the deceased consort, or the widow to receive one year’s allowance for the support of herself and children, as provided by law, unless the will expressly otherwise directs.’5

Clearly, Section 10572, General Code, expressly permitted the widow to elect to take under the will and also to take the year’s allowance and mansion house right, unless the will definitely otherwise directed, whereas, as has been stated, the exact opposite was provided in the same section as to dower and it seems certain that it is the dower right which has been, at least in part, superseded by the increased exemption provided by Section 10509-54, General Code. No authorities applicable to the exact facts presented here have been cited and the court has not found any. It seems, however, that the legislature did not intend to go so far as to make it impossible for a testator to require his widow to elect between the provision for her in his will and the exemptions provided for her by Section 10509-54, General Code.

■ The history of a similar provision in the law of Indiana is that the courts have come to hold that if the will provides for the widow and specifically disposes of all of the property in such a way that the payment of the exemption to the widow would defeat some material provision of the will, then the widow cannot take both. Shipman v. Keys, Admr., 127 Ind. 353 (1890). Bowman, Admr., v. Olrick, [221]*221165 Ind. 478 (1905). Stiglitz v. Migatz, Extr., 61 Ind. App. 529 (1916).

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Related

Nelson v. Wilson
61 Ind. 255 (Indiana Supreme Court, 1878)
Shipman v. Keys
26 N.E. 896 (Indiana Supreme Court, 1891)
Bowman v. Olrick
75 N.E. 820 (Indiana Supreme Court, 1905)
Stiglitz v. Migatz
109 N.E. 809 (Indiana Court of Appeals, 1915)

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Bluebook (online)
32 Ohio N.P. (n.s.) 217, 1934 Ohio Misc. LEXIS 1454, Counsel Stack Legal Research, https://law.counselstack.com/opinion/landfear-v-scharkofsky-ohprobctcuyahog-1934.