Newbury v. McCammant

182 N.W.2d 147, 45 A.L.R. 3d 1, 1970 Iowa Sup. LEXIS 925
CourtSupreme Court of Iowa
DecidedDecember 15, 1970
Docket54062
StatusPublished
Cited by13 cases

This text of 182 N.W.2d 147 (Newbury v. McCammant) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Newbury v. McCammant, 182 N.W.2d 147, 45 A.L.R. 3d 1, 1970 Iowa Sup. LEXIS 925 (iowa 1970).

Opinions

RAWLINGS, Justice.

By declaratory judgment action, Kenneth W. Newbury, executor of the estate of Kate E. Fults, deceased, seeks a construction of Articles VI and VII of decedent’s will, more particularly as to whether the Article VI bequest adeemed. Trial court held it did and the property involved passed as residue. Adversely affected defendants appeal. We reverse.

Plaintiff executor takes no part in these appellate proceedings. The contest here is solely between two groups of defendants. For brevity, Article VI devisees will be sometimes referred to as appellants, Article VII residuary beneficiaries as appellees.

Testatrix, by Article VI of her will, dated June 23, 1961, directed certain described real property be sold by the executor and proceeds realized therefrom distributed to appellants or their respective relatives. By Article VII she directed the residue be distributed to appellees, three of whom do not participate herein. Subsequently testatrix executed two codicils which did not change the controverted articles.

September 16, 1966, testatrix entered into a contract for sale of the real estate described in Article VI, the sale price being $65,000, payable in installments of principal plus accrued interest, last payment due January 2, 1972. Time was of the essence and buyers took immediate possession. The contract is specifically made binding on the heirs, legal representatives, successors in interest and assigns of all parties.

In May 1968, testatrix died with $37,000 principal and $574.56 accrued interest owing on the contract. There was also $3,-351.47 then on deposit in a bank, designated “Farm Account”.

[149]*149The basic issue presented on this appeal is propriety of trial court’s holding that the Article VI gift stood adeemed.

Appellants concede, as to any sale proceeds intermingled by decedent with other assets, or otherwise used by her prior to death, the ademption concept applies. They claim, however, trial court erred in holding the unpaid portion of proceeds from sale of the supporting realty adeemed and must resultantly pass with the residue.

I. The problem at hand is neither new nor novel. Commissioners of Emperor Justinian, describing the Roman law of legacies, said:

“If a testator bequeath his own property, and afterwards alien, it is the opinion of Celsus, that the thing bequeathed will become due to the legatee, if the testator did not dispose of it, with an INTENTION to oust him. The emperors Severus and Antoninus have published their rescript to this effect; and they have also signified by another rescript that a legacy afterwards pawned or mortgaged, shall not be considered as retracted; and that the legatee may bring suit against the heir and oblige him to redeem. And, if but a part of the thing bequeathed be aliened, that part which remains unal-iened, is still due; and that, which is aliened, is only due, if it appear not to have been aliened by the testator WITH A DESIGN to retract the legacy.” (Emphasis supplied) Institutes, (T. Cooper, 3rd ed.), 2.20.12.

This reasoning formed a portion of ancient Roman law relative to destruction of legacies, differing in several respects from the ultimately evolved common law. Ademption by Extinction: Its Practical Effects, 18 Wis.L.Rev. 11.

Early common law scholars relied heavily on the Roman Ademptio. Resultantly the quoted passage, inter alia, constituted a substantial basis for the common law of ademption. Ademption by Extinction: Its Practical Effects, 18 Wis.L.Rev. 11, 15-33;

The History of Ademption, 25 Iowa L.Rev. 290, 297; 6 Bowe-Parker: Page on Wills, § 54.1; 3 American Law of Property, (Casner ed.), § 14.13 at 606-607.

II. There has long been a divergence of opinion, however, as to proper operation or application of the ademption rule. Annot. 165 A.L.R. 1032. See The History of Ademption, 25 Iowa L.Rev. 290; 3 American Law of Property, (Casner ed.), § 14.13 at 607-608.

Historically the courts of this country, and England, in early times followed the dictates of Justinian, holding testator’s intention crucial to operation of the doctrine. The History of Ademption, supra at 304; Ademption by Extinction: Its Practical Effects, supra at 15-18; 3 American Law of Property, (Casner ed.), § 14.03 at 607. There then came a period during which judicial tribunals encountered troublesome problems or witnessed opportunities for abuse in application of the pure intention theory. Seeking a practical solution, they held ademption occurred, regardless of testator’s intention, if property specifically bequeathed was not found in the estate on death. See The History of Ademption, supra at 308-316; Ademption by Extinction: Its Practical Effects, supra at 18-19; cf. 6 Bowe-Parker: Page on Wills, § 54.15. We followed this strict identity theory in the case of In re Will of Miller, 128 Iowa 612, 105 N.W. 105 (1905), there holding a testamentary gift of proceeds to be realized from a postdeath disposition of specific realty was revoked by decedent’s pre-death sale of the supporting res, with mortgage taken for unpaid portion of the sale price. That position is adhered to in many jurisdictions. See 6 Bowe-Parker: Page on Wills, § 54.15. But this application of the doctrine was often harsh and frequently at odds with testator’s intention. See Id. § 54.19; Ademption by Extinction: Its Practical Effects, supra at 25-26.

More recently we have therefore taken the position, at least sotto voce, the Justinian concept of intention is involved in ap[150]*150plication of the ademption principle, coupled with reliance on identity of the thing bequeathed or devised. See In re Estate of Bierstedt, 254 Iowa 772, 775-778, 119 N.W.2d 234; In re Estate of Sprague, 244 Iowa 540, 546, 57 N.W.2d 212. See also The History of Ademption, supra at 316— 317.

This appears to be entirely proper for it has long been held the primary consideration in will construction is intent of the testator. E.g., In re Estate of Lamp, 172 N.W.2d 254 (Iowa); In re Estate of Sprague, supra 244 Iowa at 543, 57 N.W.2d 212; In re Estate of Keeler, 225 Iowa 1349, 1352-1354, 282 N.W. 362.

And we resort to technical rules or canons of construction only if the language of a will is clearly ambiguous, conflicting, or testator’s intent is for any reason uncertain. Ibid; In re Estate of Staab, 173 N. W.2d 866, 870-871 (Iowa); In re Estate of Roberts, 171 N.W.2d 269, 271 (Iowa); Wagg v. Mickelwait, 165 N.W.2d 829, 831 (Iowa). Our adherence to this precept is evident in relatively recent ademption cases. See In re Estate of Bierstedt, supra, and In re Estate of Sprague, supra. See also In re Estate of Stonebrook, 258 Iowa 1062, 1073, 141 N.W.2d 531.

III.

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Newbury v. McCammant
182 N.W.2d 147 (Supreme Court of Iowa, 1970)

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182 N.W.2d 147, 45 A.L.R. 3d 1, 1970 Iowa Sup. LEXIS 925, Counsel Stack Legal Research, https://law.counselstack.com/opinion/newbury-v-mccammant-iowa-1970.