O'Hair v. O'Hair

508 P.2d 66, 109 Ariz. 236, 1973 Ariz. LEXIS 316
CourtArizona Supreme Court
DecidedMarch 22, 1973
Docket10907-PR
StatusPublished
Cited by63 cases

This text of 508 P.2d 66 (O'Hair v. O'Hair) is published on Counsel Stack Legal Research, covering Arizona Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Hair v. O'Hair, 508 P.2d 66, 109 Ariz. 236, 1973 Ariz. LEXIS 316 (Ark. 1973).

Opinions

STRUCKMEYER, Justice.

This action for divorce was brought by Martha Kathryn O’Hair, plaintiff in the lower court, against her husband, Huston Harding O’Hair. Judgment was entered in the Superior Court granting to plaintiff a divorce, but denying an award for alimony. The Judgment also disposed of certain property asserted to be the separate property of the husband, granted support for the two minor children of $100.00 a month each, and denied any support for an adult handicapped daughter. The Court of Appeals reversed, 16 Ariz.App. 565, 494 P.2d 765 (1972). Opinion of the Court of Appeals vacated. Judgment of the Superior Court affirmed.

The parties to this divorce action were married in 1947 in Phoenix, Arizona, and [238]*238have been, until the filing of the decree of divorce on December 11, 1970, husband and wife. In 1965, defendant suffered a cerebral accident and has not been gainfully-employed since, except insofar as he managed his business investments. In September of 1968, defendant had distributed to him, from the sale of the estate of his mother in Illinois, $203,715.11, of which he placed $150,000.00 in a savings account with the Western Savings and Loan Association in joint tenancy with right of survivorship. A signature card was executed so stating. Forty thousand dollars was placed in a certificate of time deposit with right of survivorship in the names of himself and plaintiff. Thereafter, both parties drew from the savings account, the plaintiff keeping possession of the passbook. Prior to the commencement of the divorce, the plaintiff wife made a withdrawal of $75,000.00 from the savings account and $25,000.00 held in their joint names under certificate of deposit. With these, on October 4, 1969, she established in the United Bank in Phoenix a revocable trust with herself as beneficiary.

The trial court found that the $100,000.-00 was the separate property of the defendant and entered a judgment favorable to him, pursuant to the authority of A.R.S. § 25-318, providing that neither party shall be divested of his separate property in a divorce action.

It is settled in Arizona that where a person deposits 'money in a bank to the credit of himself and another, payable to the order of either, or the survivor of them, such deposit vests in the other a joint interest with the depositor in the fund. Any question as to the extent of the other’s interest is determined from the intention of the depositor — whether a gift was intended or whether the joint tenancy transaction was entered into for other purposes. Saylor v. Southern Arizona Bank and Trust Company, 8 Ariz.App. 368, 446 P.2d 474 (1968); Phoenix Title & Trust v. King, 58 Ariz. 477, 121 P.2d 429 (1942); McNabb v. Fisher, 38 Ariz. 288, 299 P. 679 (1931). In this, Arizona follows the general rule in the United States where not otherwise changed by statute. See, e. g., Harrington v. Emmerman, 88 U.S.App D. C. 23, 186 F.2d 757 (1950); Juraitis v. Andriulis, 318 Mass. 782, 64 N.E.2d 701 (1945); Erickson v. Kalman, 291 Minn. 41, 189 N.W.2d 381 (1971); Tucker v. Tucker, 252 Miss. 344, 173 So.2d 405 (1965); Clabbey v. First National Bank, 320 S.W.2d 738 (Mo.App.1959); Esposito v. Palovick, 29 N.J.Super. 3, 101 A.2d 568 (1953); Laurent v. Williamsburgh Savings Bank, 28 Misc.2d 140, 137 N.Y.S.2d 750 (1954); In re Berzel’s Estate, 101 N.W.2d 557 (N.D.1960); Wynne v. Wynne, 69 R.I. 229, 33 A.2d 173 (1943); Quesenberry v. Funk, 203 Va. 619, 125 S.E.2d 869 (1962).

While as between the bank and the depositor the contract of deposit is conclusive, the mere form of the bank account is not regarded as sufficient to establish the intent of the depositor to give another a joint interest in or ownership of the deposit. Bolton v. Bolton, 306 Ill. 473, 138 N.E. 158 (1923); Ball v. Forbes, 314 Mass. 200, 49 N.E.2d 898 (1943); Hodgins v. Zabel, 7 Misc.2d 484, 166 N.Y.S.2d 135 (Sup.Ct.1957); Industrial Trust Co. v. Taylor, 69 R.I. 62, 30 A.2d 853 (1943). As the court said in Cashman v. Mason, 72 F.Supp. 487, 492 (D.Minn.1947):

“Joint accounts are a common method of handling funds in a bank as between husband and wife and others for mutual convenience and economy, but without necessarily intending to bestow any present interest in the fund on the one who is joined for the convenience of the owner of the moneys deposited.”

“[T]he intention of the depositor is controlling.” McNabb v. Fisher, supra, 38 Ariz. at 295, 299 P. at 681.

The trial court found that appellee “did not intend at any time to change the character as sole and separate property of the funds which were deposited by him at Western Savings and Loan Association.” This [239]*239finding is predicated at least in part on the testimony of the defendant:

On direct examination:

“Q Mr. O’Hair, when you established this account at Western Savings, for example, you put it in your joint names, is that correct?
A That is right.
Q Did you intend to give that money to your wif e ?
A No, I did not, sir.
Q What was your intention, why did you put both names, then, Mr. O’Hair?
A In the event something happened to me, * * * it would be easier for her to go up and draw some out to live on. Now, I am talking about in the event of my death.”

On cross examination:

“Q Well, you did ask her, though, Mr. O’Hair, to withdraw sums of money and put them in the Valley Bank checking account, didn’t you ?
A I said whatever was necessary for living expenses, and also — ■
H* 'S* *4» *5»
Q Mr. O’Hair, looking at those records, isn’t it true you didn’t tell your wife she could not make withdrawals from that account? She could make withdrawals from that account at Western Savings whenever she wanted to, couldn’t she ?
A She could make withdrawals for household expenses.”

Defendant’s testimony tends to suggest that this was their understanding. She was asked this question:

“Q * * * what I am asking you is what were the checks drawn on this particular account used for, for the most part?
A Living expenses.”

Both plaintiff and defendant made withdrawals from the account. Her withdrawals were usually deposited to the parties’ joint checking account from which household and living expenses were paid. However, in September, 1969,' a year after opening the account, Mrs. O’Hair withdrew the $75,000.00.

A bank account opened or carried in the name of two or more persons is in their joint custody. Joint custody of an account is a fact which, in itself, negatives any idea of a gift, In re Betts’ Estate, 122 N.Y.S.2d 234, 235-236 (Sur.1953), since the essential element of a gift of personal property requires an intent on the part of the donor to divest himself of all dominion and control.

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Cite This Page — Counsel Stack

Bluebook (online)
508 P.2d 66, 109 Ariz. 236, 1973 Ariz. LEXIS 316, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ohair-v-ohair-ariz-1973.