Sanford Estate

41 Pa. D. & C.3d 343, 1984 Pa. Dist. & Cnty. Dec. LEXIS 31
CourtPennsylvania Court of Common Pleas, Bucks County
DecidedOctober 25, 1984
Docketno. 47905
StatusPublished

This text of 41 Pa. D. & C.3d 343 (Sanford Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Bucks County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanford Estate, 41 Pa. D. & C.3d 343, 1984 Pa. Dist. & Cnty. Dec. LEXIS 31 (Pa. Super. Ct. 1984).

Opinion

MIMS, J.,

The first and final account of Gerald E. Bloom, III, administrator of the estate , of said decedent, was presented to the court for audit, confirmation and distribution of ascertained balances on May 7, 1984, as advertised according to law. Due proof of appropriate notice thereof to all parties legally interested in said estate appears in the record.

Said account has been examined and audited by the court. Balances for distribution shown thereby [344]*344include principal in the amount of $75,800 composed of cash, and income in the amount of $8,044.07 in cash. Said respective balances for distribution appear to have been correctly computed and stated on the accounting filed.

No additional receipts or disbursements since the accounting were suggested.

No information has been found in this record concerning the payment of inheritance tax. Accordingly, the awards hereinafter directed are made subject to such liability, if any, as may still in fact be due thereon for transfer inheritance tax.

This estate has been fraught with many problems since its inception. Ronald Sanford died intestate on March 25, 1976, and letters of administration were granted to Robert Rovner by the Register of Wills of Bucks County on April 9, 1976. Lynn Horton filed a petition to the register of wills to vacate those letters and grant letters of administration to her claiming that she was the common-law wife of decedent. The register of wills rendered a decision finding no common-law marriage and refusing to vacate the letters of administration granted to Robert Rovner. Lynn Horton appealed from the decision of the register relating to the common-law marriage. On August 2, 1984, we entered a decree nisi denying her appeal. Timely exceptions were filed and by a final decree entered this date, those exceptions are denied.

A petition was presented to this court asking that Robert Rovner be removed as administrator. After hearing, we entered an order on May 12, 1981, removing Robert Rovner as administrator and authorized the register of wills to appoint Gerald E. Bloom, III, as administrator. He was appointed administrator by the register on February 17, 1984.

It should be noted that Lynn Horton is the mother of two minor children: Kelly Ann Horton and Ron-[345]*345aid Francis Sanford, Jr., and decedent is the father. The issue of these two children will be addressed later on in this adjudication.

During the course of this estate we appointed Edmund P. Butler, Esq., as guardian ad litem for Kelly Ann Horton and James J. Martin, Esq., as guardian ad litem for Ronald Francis Sanford, Jr. These two attorneys have participated in all thé litigation generated by this estate.

Decedent also was survived by his father, Charles A. Sanford, and his mother, Ann Sanford Damiano.

The accountant in his petition for adjudication has suggested that the entire estate be distributed to Ann Sanford Damiano and Charles A. Sanford, decedent’s parents.

Objections have been filed on behalf of the minor children, Kelly Ann and Ronald, Jr., who were born out of wedlock. In open court it was stipulated by all counsel that these children are, in fact, the children of decedent and Lynn Horton. Briefs have been filed by counsel for all the parties and we now address this issue.

Having found that Lynn Horton Sanfqrd was not the common-law wife of decedent, we are next faced with the issue of whether or not Kelly Ann Horton and Ronald Francis Sanford, Jr., both born out of wedlock, are entitled to take under the Pennsylvania law of intestacy.

The statutory law in effect in Pennsylvania on this issue at the time of decedent’s death on March 25, 1976, was §2107 of the Probate Code, 20 Pa.C.S. §2107, which provided that an illegitimate child could not inherit from or through his father. However, the United States Supreme Court in Trimble v. Gordon, 430 U.S. 762, 97 S.Ct. 1459, 52 L.Ed. 31 (1977), held that a similar provision in the Illinois intestate act was unconstitutional.

[346]*346Since that decision in Trimble, the following cases and statutory amendments have shaped Pennsylvania law. In Browning Estate, 28 Fid. Rep. 1 (1977), Judge Shoyer of the Orphans’ Court Division of the Court of Common Pleas of Philadelphia held §2107 of the Pennsylvania Probate Code to be unconstitutional in that it violated the Equal Protection Clause of the Fourteenth Amendment of the United State's Constitution by invidiously discriminating on the basis of legitimacy.

The United States District Court for the Eastern District of Pennsylvania, in Fernandez et al. v. Shapp et al., 28 Fid. Rep. 359 (1978), entered an order and consent agreement which stated, inter alia, that section 2107 of the Probate Code was violative of the Equal Protection Clause of the Fourteenth Amendment insofar as it discriminated against children born out of wedlock so as to bar those children from intestate succession to their fathers’ estates.

By act of November 26, 1978, P.L. 1269 §1, the Pennsylvania legislature amended section 2107 of the Probate Code as follows:

“(c) Child of father — For purposes of descent by, from and through a person born out of wedlock, he shall be considered the child of his father when the identity of the father has been determined in any one of the following ways:

“(1) If the parents of a child born out of wedlock shall have married each other.

“(2) If during the lifetime of the child, the father openly holds out the child to be his and receives the child into his home, or openly holds the child out to be his and provides support for the child which shall be determined by clear and convincing evidence.

“(3) If there is clear and convincing evidence that the man was the father of the child, which may include a prior court determination of paternity.” [347]*347The legislature made Act 303 effective immediately but specifically provided that the act would hot apply to wills executed prior to the effective date or “to rights from and through a child’s father if the father had died prior to the effective date of this act.” Act 303, supra, §5.

In Fleming Trust, 30 Fid. Rep. 545 (1980), Judge Ross of the Orphans’ Court Division of the Court of Common Pleas of Allegheny County held that the mere fact that a child born out of wedlock could not assert her right under amended §2107 of the Probate Code because her father had died in 1951, prior to Act 303, did not mean that she was barred from proving her claim by clear and convincing evidence of paternity. Judge Ross stated at 550:

“The statutes applicable at the time the will was executed and at the death of Alexander P. Lyon, IV, violated the equal protection clause of the Fourteenth Amendment to the United States Constitution: Act of April 27, 1855, P.L. 368 §3; Intestate Act of April 24, 1947, P.L. 80 §7. See Dulles Trust, 29 Fiduc. Rep. 141, 149. There is no reason not to permit proof of petitioner’s right at the pending audit since it is not asked that prior distributions decreed under prior audits are to be set aside. Wé are applying the rule of this case prospectively as to pending and future audits, not retroactively.”

This court in Hardiman Estate, 30 Fid. Rep. 561 (1980), also allowed the child born out of wedlock to go forward to attempt to prove his claim, which he ultimately failed to do.

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Related

Trimble v. Gordon
430 U.S. 762 (Supreme Court, 1977)
Estate of Hoffman
466 A.2d 1087 (Supreme Court of Pennsylvania, 1983)
Estate of Dulles
431 A.2d 208 (Supreme Court of Pennsylvania, 1981)

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41 Pa. D. & C.3d 343, 1984 Pa. Dist. & Cnty. Dec. LEXIS 31, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanford-estate-pactcomplbucks-1984.