Mailey Estate

51 Pa. D. & C.2d 259, 1970 Pa. Dist. & Cnty. Dec. LEXIS 293
CourtPennsylvania Court of Common Pleas, Philadelphia County
DecidedOctober 13, 1970
Docketno. 590 of 1970
StatusPublished
Cited by2 cases

This text of 51 Pa. D. & C.2d 259 (Mailey Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mailey Estate, 51 Pa. D. & C.2d 259, 1970 Pa. Dist. & Cnty. Dec. LEXIS 293 (Pa. Super. Ct. 1970).

Opinion

KLEIN, Adm. J.,

The reason for filing the present account is the death of John V. Mailey, settlor, on October 18, 1969. There has been no prior adjudication of this trust.

The relevant dispositive provisions of the indenture of trust and all other necessary facts pertaining to the [260]*260terms of the trust are set forth in the statement of proposed distribution. . .

John V. Mailey, the settlor, and his wife, Anne F. Mailey, were divorced on October 2, 1969. He committed suicide 16 days later on October 18, 1969. Two questions are submitted by the accountants in the statement of proposed distribution as requiring adjudication because of the divorce:

1. Is Anne F. Mailey to be considered a party beneficially interested in the trust and entitled to the payment of principal or income therefrom, or is she to be precluded therefrom because of her divorce from John V. Mailey prior to his death?

2. Does Anne F. Mailey, divorced spouse of decedent, have the right to proceed as cotrustee under the deed of trust?

The trustees take the position that the wife’s divorce “from the settlor just prior to his death does not in any way prevent her from serving as cotrustee, nor does it exclude her from a beneficial interest in the trust.” We are in full accord with these conclusions.

RIGHT OF ANNE F. MAILEY TO RECEIVE BENEFITS

The fact that Anne F. Mailey was divorced from the settlor at the time of his death is not in itself an impediment which would prevent her from receiving the benefits given to her under the trust instrument. True, section 7(2) of the Wills Act of April 24, 1947, P. L. 89, 20 PS §180.7(2), as amended, provides that if a testator is divorced from the bonds of matrimony after making a will, all provisions in the will in favor of, or relating to, his spouse so divorced shall thereby become ineffective for all purposes. But the writing before us is not a will. It is a revocable inter vivos trust which was not revoked by the settlor. Moreover, [261]*261the trust res consists entirely of the proceeds of life insurance policies issued upon settlor’s life which are expressly made “not testamentary” by section 8 of the Estates Act of April 24, 1947, P. L. 100, as added by the Act of July 11, 1957, P. L. 792, 20 PS §301.7a. It is therefore clear that section 7(2) of the Wills Act does not apply.

Two arguments can be advanced in support of the position that Anne F. Mailey is barred from receiving any benefits from the trust: (1) the distributive plan sets up a marital trust which is predicated upon Anne F. Mailey being his wife when settlor died; and (2) she is referred to in the trust instrument by the settlor as “his wife, Anne F. Mailey” and as “Anne F. Mailey, wife of settlor,” thus indicating that she was to participate only if she was his wife when the trust became operative.

The provisions in the deed of trust creating a marital trust for his wife appear to be wholly inappropriate to the situation which actually existed when settlor died. Since the parties were divorced, the marital trust provided by Item First fails because the marital status did not exist when the instrument became effective. However, settlor provided in Item Second, that “after allocating to the Trust under Item First the percentage, if any, of the principal held hereunder which may be required to satisfy the provisions of Item First, Trustee shall hold the balance of such principal in trust, and pay to settlor s wife during her life the income derived therefrom.” (Italics supplied.)

Since the marital trust was inoperative, it follows that the entire principal becomes available for funding the trust under Item Second to furnish income to the wife for life.

It is clear that the language used in the deed of trust when referring to Mrs. Mailey, and the effect [262]*262of the divorce on the dispositive provisions thereof, raise serious questions as to what settlor’s intentions were. Since we are not aware of any statutory or decisional bar to the right of Mrs. Mailey to receive benefits under the trust, we must try to construe the instrument in the light of all of the surrounding circumstances.

The guide lines to be followed in resolving questions of this nature were laid down by Mr. Justice Jones, in Erny Trust, 415 Pa. 8 (1964), in which case settlor created a trust while he was married to Agnes. Subsequently, they were divorced and he married Mary. Upon his death, the question arose whether a gift of one-half of the trust income to “ ‘the wife of [settlor], living at the time of his death’ ” went to Agnes or Mary. The court ruled that (1) the determination of the question must arise from the consideration of the language and scheme of distribution of this particular trust instrument considered in the light of all the circumstances under which this trust instrument was made; (2) there is no inflexible rule of construction or any presumption arising from the use of the word “wife”; (3) the intent of the settlor evidenced by the language and scheme of the trust instrument, viewed in the light of the circumstances in which the trust instrument was created, must control; (4) the identification of the person intended by the word “wife” must be determined by the language and scheme of the particular instrument viewed in the light of the circumstances existing at the time of its execution. The court concluded that the circumstances under which settlor executed this trust deed, and his scheme providing for the ultimate disposition of the one-half share of the income given to the “wife of settlor,” initially leads to the conclusion that he intended by the word “wife” the only “wife” he then knew, Agnes.

In the present case, the settlor and his wife were [263]*263married on July 2, 1949. Seven children were born of the marriage, ranging in ages from nine years to 20 years. They all reside with their mother in a common household and she supports them. One of the children has a chronic kidney condition and another requires costly schooling by reason of severe reading problems. The settlor was an alcoholic and his drinking ruined his marital relationship. He tried very hard but unsuccessfully to control his illness through psychiatry and Alcoholics Anonymous and was on two occasions hospitalized at the. Norristown State Hospital. He took his own life in a Spruce Street hotel and left a tender, poignant holographic note which explains his feelings towards his wife and his intention with respect to the distribution of the trust he created.

The note reads:

“Dear Anne:
“Life without you and the kids is not worth living—
“No one is to blame but me. The day of the trial I decided the world would be better off without me. How someone can go from not wanting booze in the house to an animal is amazing.
“This is the only way I know to get you the money that you need and freedom from me.
“You may not believe it but I love you and the kids and always have.
“Sorry I flunked so badly but I tried and tried hard.
“The kids are something to be proud of. I hope you get a man who appreciates you and them — you were always a good wife to me — and this way you’ll at least get insurance — social security, and won’t have to worry about a derelict harassing you.

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Related

Adams Estate
288 A.2d 514 (Supreme Court of Pennsylvania, 1972)

Cite This Page — Counsel Stack

Bluebook (online)
51 Pa. D. & C.2d 259, 1970 Pa. Dist. & Cnty. Dec. LEXIS 293, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mailey-estate-pactcomplphilad-1970.