Sears v. Sears

77 Ohio St. (N.S.) 104
CourtOhio Supreme Court
DecidedNovember 19, 1907
DocketNo. 10122
StatusPublished

This text of 77 Ohio St. (N.S.) 104 (Sears v. Sears) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sears v. Sears, 77 Ohio St. (N.S.) 104 (Ohio 1907).

Opinion

Summers, J.

In this state the right of disposing of property by will is given, and the manner of exercising it is prescribed by statute. The provisions of the Revised Statutes bearing upon the questions to be determined, may be briefly summarized as follows: Section 5914 prescribes who may make a will; Section 5916, providing how a will shall be executed, is as follows: “Every last will and testament (except nuncupative wills here[117]*117inafter provided for) shall be in writing, and may be hand-written or typewritten; and such will shall be signed at the end thereof by the party making the same, or by some other person in his presence and by his express direction, and shall be attested and' subscribed, in the presence of such party, by two or more competent witnesses, who saw the testator subscribe, or heard him acknowledge the same.” Section 5926 provides, when application has been made to admit a will to probate, that the probate court shall cause the witnesses to such will, and such other witnesses as any person interested in having the same admitted to probate may desire, to come before it, and that the witnesses shall be examined in open court and their testimony reduced to writing and filed. Section 5929 is as follows: “If it shall appear that such will was duly attested and executed, and that the testator, at the time of executing the same, was of full age and of sound mind and memory, and not under any restraint, the court shall admit the will to probate.” Section 593° provides that when admitted to probate the will shall be filed in the office of the probate judge and recorded, together with the testimony. Section 5933 provides that if no person interested shall contest the will within two years, the probate shall be forever binding, saving to infants and persons of unsound mind or in captivity, a like period after the disabilities are removed. Section 5936 enacts that whenever the probate court shall receive from the clerk of the court of common pleas a certificate that a petition has been filed in the court- of common pleas to contest the [118]*118validity of any will recorded in the probate court, the probate court shall forthwith transmit to the court of common pleas the will, testimony and all papers relating thereto, with a copy of the order of probate and a certificate under the seal of the court. Section 5858 provides that a person interested in a will admitted to probate may contest the validity thereof in a civil action in the court of common pleas of the county in which such probate was had. Section 5859' provides who shall be parties. Section 5861 provides how an issue shall be made up, whether the writing produced is the last will or codicil of the testator or not, and that this issue shall be tried by a jury, and that the verdict therein shall be conclusive, unless a new trial be granted or the judgment be reversed or vacated. Section 5864 provides that “the party sustaining the will shall be entitled-to open and close the evidence and argument; he shall offer the will and probate, and rest; the opposite party shall then offer his evidence; the party sustaining the will shall then offer his other evidence; and rebutting testimony may be offered as in other cases.” Section 5862 provides that on the trial of such issue, the; order of probate shall be prima facie evidence of the due attestation, execution and validity of the will or codicil.

The first contention is that the will is not a valid will because it is partly in printing.

“Part Third” of the Revised Statutes includes Section 5916, and Section 4947 provides that in the interpretation of Part Third, unless the context shows that another sense was intended, the word “writing” includes printing. Before the [119]*119amendment of Section 5916, in 1895, 92 O- L., 189, that section did not contain the words “and may be hand-written or typewritten,” and the law then was that a will might be written or printed. Counsel contend' that since the amendment the context shows that another sense was intended, and that writing means only hand-written or typewritten, and that the effect of the amendment was not merely to authorize a typewritten will, but also to exclude a printed will. Typewriting has come into general use since the revision of the statutes in 1880, and the manifest intention of the legislature was to authorize its use in addition to handwriting and printing in the making of wills, and not to substitute typewriting for printing; so that a will is not invalid because it is partly in print.

The next question is, is the will signed at the end thereof by the party making the same? By the Act of 1816, 2 Chase’s Statutes, 929, and the Act of 1831 (29 O. L., 242), wills were required to be in writing, and signed by the party making the same, and not until the Act of 1840 (38 O. L., 120) took effect were wills required to be signed at the end thereof. This requirement is assumed to have been suggested by the English statute of wills, passed in 1837, although such a requirement had been previously enacted by statute in New York and in Pennsylvania. The English statute is to be found in 1 Vict.,-c. 26. Section 9 of that act provides that no will shall be valid unless “it shall be signed at the foot or end thereof by the testator, or by some other person in his presence, and by his direction.” In Williams [120]*120on Executors, 107 (7 Am. ed.), the learned author, speaking of this requirement, says:

“The will is required by that act to be signed ‘at the foot or end thereof.’ The Statute of Frauds merely requires that the will shall be ‘signed’; and it was held that a will in the testator’s own handwriting, commencing, T, John Styles, do declare this to be my last will, etc.,’ was sufficiently ‘signed’ within that statute, although not subscribed with his name. With a view, perhaps, to prevent future controversy as to whether a will so signed is a complete and perfect instrument, the statute of Victoria required that the signature of the testator shall be at the foot or end of the will.
“But questions of this kind do not appear to be altogether excluded by the operation of this enactment. And a new ground of contest arose out of it, as to. what may be considered a signing of the will at the end or foot thereof.
“Doubts arose whether a signature by the testator in the body of the testimonium or attestation clause was sufficient; and also, whether a signature below the latter clause, when it runs beneath the conclusion of the will, was a compliance with the act. On the question whether the will was well executed, if there was a folank space between the conclusion of the will and the signature of the testator, a lamentably large number of points and decisions occurred-. In the earlier cases Sir H. Jennor Fust put a very liberal construction on this part of the act. But afterwards that learned judge, in concurrence with the Judicial Committee of the Privy Council, felt it necessary to take [121]*121a more rigid view of this enactment, on the ground that it was intended to prevent any addition being made to the will after the deceased had executed it. And accordingly probate was refused in a great number of subsequent cases on this objection, and the intention of a great many testators unfortunately defeated.
“This led to the passing of the Stat. 15 Vict., c. 24.”

The amendatory act passed in 1852, 15 Vict., c.

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Bluebook (online)
77 Ohio St. (N.S.) 104, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sears-v-sears-ohio-1907.