Polk v. Linthicum

2 Balt. C. Rep. 99
CourtBaltimore City Superior Court
DecidedAugust 6, 1900
StatusPublished

This text of 2 Balt. C. Rep. 99 (Polk v. Linthicum) is published on Counsel Stack Legal Research, covering Baltimore City Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Polk v. Linthicum, 2 Balt. C. Rep. 99 (Md. Super. Ct. 1900).

Opinion

HARLAN, J.—

Article 93 of the Code of Public General Laws, title “Testamentary Law,” contains among others the following sections:

“238. If an administrator shall believe that any person conceals any part of his decedent’s estate, he may file a petition in the Orphans’ Court of the county in which he obtained administration, alleging such concealment, and the Court shall compel an answer thereto on oatli, and if satisfied, upon an examination of the whole case, that the party charged has concealed any part of the personal estate of the deceased, may order the delivery thereof to the administrator, and may enforce obedience to such order by attachment, imprisonment or sequestration of property.”
“239. The provisions of the aforegoing section are extended to all cases where any person interested in any decedent’s estate shall by bill or petition allege, that the administrator has concealed or has in his hands, and has omitted to return in the inventory or list of debts any part of his decedent’s assets, and if the Court shall finally adjudge and decree in favor of the allegations of such petition or bill, in whole or in part, they shall order an additional inventory or list of debts, as the case may be, to be returned by the administrator and appraisement to be made accordingly to comprehend the assets omitted, and such additional inventory or list of debts shall have the same effect to all intents and purposes as any inventory or list of debts before returned, and the Court may compel obedience to said order by attachment and imprisonment and sequestration of' property, and if the said administrator shall either before or after such process of attachment, imprisonment and sequestration, fail to comply with such order, his letters of administration may be revoked and the Court may direct his bond to be put in suit, and the assets ordered to be comprised in such additional inventory or list of debts shall be decreed and taken to be within the condition of said bond.”
“240. If, upon the answer to any petition or bill filed under the provisions of the two preceding sections, either party shall require it, the Court shall cause an issue, or issues, to be made up and sent to the Circuit Court for the County, or the Superior Court of Baltimore City, the Court of Common Pleas or the Baltimore City Court, as the case may be, to be there tried and disposed of, as other issues from the Orphans’ Court, and either party to such bill or petition may appeal to the [100]*100Circuit Court for the County or the Superior Court of Baltimore City.”

These sections give to the Orphans’ Court jurisdiction over two classes of cases: The first, under Section 238, where an administrator alleges that any person conceals any part of his decedent’s estate. The second, under Sec. 240, where any person interested in any decedmt’s estate alleges that the administrator has concealed, or has in his hands, or has omitted to return in the inventory or Ust of debts, any part of his decedent’s assets.

In the first class, the jurisdiction of the Court depends entirely upon concealment. Without concealment of the decedent’s personal property being alleged, the Orphans’ Court would be without jurisdiction to entertain the petition in the first instance, and without concealment being proven, it would be without jurisdiction “to order the, delivery thereof to the administrator.”

It was ruled in Taylor vs. Bruscup, 27 Md. 219, that secrecy is an essential element of the concealment meant by this section that something more than the withholding of property belonging to the estate is necessary. “It *can scarcely be imagined,” say the Court, “that the extraordinary power of requiring an answer upon oath, with the summary process of attachment, sequestration and commitment, were to be exercised by a Court of special limited jurisdiction in every case in which the administrator or executor should allege a tim'd person withheld property winch belonged to the estate of the deceased.” And following this case it was decided in Gibson vs. Cook, administrator, 62 Md. 256, where the answer of the third person to the administrator’s petition alleging concealment, admitted the possession of the money claimed by the administrator and claimed it as his own property, that the pleadings raised an issue of title, not of concealment, and the Orphans’ Court had properly decided “that under such a state of facts that Court had no jurisdiction, because it could not decide a question of title.” But in the second class, where the administrator is respondent, the withholding of property belonging to the estate, by the latter, and his failing to return the same in the inventory or list of debts, is made a distinct source of jurisdiction the language is alternative. “Where any person interested * * * shall allege that the administrator has concealed, or has in his hands and has omitted to return in the inventory or Ust of debts aivy part of his decedent’s assets.” The grant of jurisdiction here is plain and unmistakable. The petitioner must allege either that the administrator has concealed or that he has in his hands and has omitted to return property of his decedent.

If these allegations are made in the petition the statute has been complied with. It is the truth of these allegations that is to be investigated.

There is no room for the contention that the mere withholding of property belonging to the estate, without secrecy, is not concealment and does not give a remedy in the Orphans’ Court against the administrator, because the statute expressly says that it does. It was certainly competent for the Legislature to confer this jurisdiction upon the Orphans’ Court, preserving the right of jury trial by providing for the framing issues to be sent to a Court of law, as has been done; and it seems to me impossible, to maintain successfully that the Orphans’ Court cannot, under this section, decide the title to personal property in the possession of the administrator, alleged to be assets of the estate which he conceals or withholds. If the property involved does not belong to the estate there can be no withholding of it as against those whose sole interest in it arises out of their interest in the estate, and, on the other hand, if the property does belong to the estate and has been omitted- from the inventory or list of debts, it has been withheld. The title of the property is the vital question. And while it was ruled, as above noted, -under Section 238, that the Orphans’ Court could not, as between the administrator and a third person decide the title to property, which the latter admitted to be in Ms - possession, but claimed as his own, because there was no issue of concealment, the Court of Appeals has nowhere held that under Section 239, where the administrator is the respondent, and the petitioner is a person interested in the estate, the Orphans’ Court is without jurisdiction to decide whether the property which is alleged to be withheld is property which should be included in the estate, or is property belonging to the administrator, or held by him in some other right, which [101]*101should not be Included. On the contrary, that Court, in Whiling vs. Whiting, 64 Md. 157, pointed to this section as conferring ample power upon the Orphans' Court to determine whether an administrator owed money to the ('state and had not returned the debt as he should have done.

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Related

Taylor v. Bruscup
27 Md. 219 (Court of Appeals of Maryland, 1867)
Hignutt v. Cranor
62 Md. 216 (Court of Appeals of Maryland, 1884)
Gibson v. Cook
62 Md. 256 (Court of Appeals of Maryland, 1884)
Whiting v. Whiting
20 A. 1030 (Court of Appeals of Maryland, 1885)
Stanley v. Safe Deposit & Trust Co.
40 A. 53 (Court of Appeals of Maryland, 1898)

Cite This Page — Counsel Stack

Bluebook (online)
2 Balt. C. Rep. 99, Counsel Stack Legal Research, https://law.counselstack.com/opinion/polk-v-linthicum-mdsuperctbalt-1900.