Quay v. Quay

4 Ohio N.P. (n.s.) 529, 16 Ohio Dec. 435, 1906 Ohio Misc. LEXIS 19
CourtCuyahoga County Common Pleas Court
DecidedJanuary 29, 1906
StatusPublished

This text of 4 Ohio N.P. (n.s.) 529 (Quay v. Quay) is published on Counsel Stack Legal Research, covering Cuyahoga County Common Pleas Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Quay v. Quay, 4 Ohio N.P. (n.s.) 529, 16 Ohio Dec. 435, 1906 Ohio Misc. LEXIS 19 (Ohio Super. Ct. 1906).

Opinion

Phillips, J.

Motion to direct a verdict.

This is an action to contest the validity of the will of Robert C. .Quay, on two grounds: First, want of testamentary capacity; and second, the exercise of undue influence. The trial has proceeded in the statutory order, until the contestant has rested his case, and tjie defendants move the court to direct a verdict for them. On the argument of the motion, counsel for plaintiff abandons the second ground of contest — the exercise of undue influence — but contends that there is a scintilla of evidence in support of the other ground. The consideration of this motion calls for a determination of the legal effect of the evidence, under what is commonly known as the “scintilla rule.”

I shall not speak of the evidence in detail, nor at length. The most that can be claimed from the evidence is, that some of it shows the testator to have been of weak mind. He certainly was eccentric; was doubtless below the average of intelligence, while some of the evidence shows him to have been of sound mind. The testimony of the only doctor that testified — and he had as [530]*530good opportunity to judge of his mental condition as any witness — is to the effect that he was of sound mind at the time he made this will. Much of the testimony relates to times more or less remote from the time of the making of the will. There is no evidence as to whether at the time he made his will he knew what property he had or that he did not know what property he had. There is no evidence upon the question as to whether he knew who were his nearest relatives, and therefore the natural objects of his bounty. There is no evidence bearing upon the question as to whether he understood what disposition of his property he was actually making.

Now, these are the criteria of testamentary capacity. The will itself, so far as it may be considered upon this question, indicates nothing out of the ordinary in his capacity, or in the disposition of his property. lie had no wife living, and he had no children. His nearest relatives were two brothers, parties litigant here, and he gave all of his property to these two brothers, in unequal portions. Under the evidence there is scarcely ground for suspicion as to want of testamentary capacity; much less is. there ground for a finding based upon proof.

If, under the law, the court may weigh this evidence — may consider its probative value and effect — it is clear that no rational view of this evidence would warrant the jury in finding for the plaintiff. If, on the other hand, the court may not consider the probative value and effect of the evidence, then; I suppose, the case should go to the jury, that it may weigh the evidence, for, while there is no evidence directly bearing upon the elements of testamentary capacity, there is evidence tending to show mental capacity; and this, being admitted because it is competent upon the issue as to testamentary capacity, would properly be before the jury for consideration upon that issue, if the case should go to the jury.

To determine how far the proper functions of the judge extend in this matter, we must determine the meaning and effect of the rule under consideration. I think I may safely say that there is, both with the bar and with the bench, a strong and growing sentiment against the scintilla rule, as it has been applied [531]*531generally by our courts; and I think there is a disposition on the part of the courts to break away from it. The rule does not obtain-in England, it does not obtain in any of our federal courts, and it obtains in only a very few of our state courts; but it has always obtained in Ohio. There has been a somewhat general outcry against it. The law publications have written' against it, judges have scolded about it, and I believe our state bar association has more than once resolved against it. When the matter was last before our Supreme Court, four of the judges adhered to the rule, and the other two dissented in strong terms. There can be no doubt that the scintilla rule, as it has been generally understood and applied, has worked a decided hindrance to the speedy and effectual administration of justice in our courts. I think the profession has come to regard this rule as a relic that ought to be relegated. Of course, these considerations do not affect the rule itself; but this consensus of the legal and judicial mind, in which it is well known I have to some extent shared, has induced me to give the subject a somewhat careful consideration; and from such consideration, I am well convinced that there is no place in our jurisprudence for the scintilla rule, as it is commonly understood, and as it is generally applied.

I will consider first, the object of the rule of procedure which empowers the judge to control the jury by directing a verdict upon the evidence. It must be borne in mind that this question is presented in this case by the application of the defendant to the court, to determine whether or not he should proceed with his defense. The defendant virtually says to the court:

“I desire the judgment of the court now upon the present state of the case. Has anything been shown on the part of the plaintiff, he having put in all of his evidence, that changes the situation, or that calls upon me to meet it with evidence, with proof ?’’

This is a recognized - practice; ' it has been recognized in all time. The court is now confronted with that question, and must determine it upon principles consistent with the rights of both parties, and consistent with settled rules of procedure.

[532]*532Courts are organized and maintained to determine real controversies, and only such real controversies as' apparently have legal merit on both sides of the contention. To this end pleadings are required; to this end a censorship of the pleadings is provided, by motion and demurrer, to obtain, in advance of a trial, the judgment of the court as to whether there is a real controversy, having apparently legal merit on both sides. And whenever, during the trial, it appears to the court that there is no real controversy to be tried, the court may, and should, stop the trial. The court may exclude any and all evidence at the outset of the trial, on the ground that the plaintiff has not stated any right of action, has not come 'in with a complaint that entitles him to the intervention of the court. The court may arrest the ease, perhaps, at any stage of it before it goes to the jury, and direct a verdict for the defendant, when it is clear that the plaintiff can not have a verdict rightfully. The court may arrest judgment after a verdict; the court may always stop the trial of a case when it appears in any way, when it comes to the knowledge of the court in any way, that the court has not jurisdiction, because the trial would necessarily be fruitless— because there is nothing to be tried; there is no real controversy before a real tribunal having jurisdiction over it.

A case was heard in this room within a few daj'B, where the plaintiff was called to the stand, and from his own testimony it appeared that he was not the real party prosecuting the case. He did not have any law suit here; he was not in favor of it; he never had been in favor of it; he did not claim anything from it. A certain lawyer and a certain doctor had gone to him, he not understanding the English language, and procured him to make his mark to the petition. A motion was made to dismiss the case, and it was promptly dismissed.

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Bluebook (online)
4 Ohio N.P. (n.s.) 529, 16 Ohio Dec. 435, 1906 Ohio Misc. LEXIS 19, Counsel Stack Legal Research, https://law.counselstack.com/opinion/quay-v-quay-ohctcomplcuyaho-1906.