Trull v. Patrick

22 Ohio N.P. (n.s.) 385, 31 Ohio Dec. 319, 1920 Ohio Misc. LEXIS 14
CourtClark County Court of Common Pleas
DecidedJanuary 19, 1920
StatusPublished

This text of 22 Ohio N.P. (n.s.) 385 (Trull v. Patrick) is published on Counsel Stack Legal Research, covering Clark County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trull v. Patrick, 22 Ohio N.P. (n.s.) 385, 31 Ohio Dec. 319, 1920 Ohio Misc. LEXIS 14 (Ohio Super. Ct. 1920).

Opinion

Geiger, J.

Tbe plaintiff in ber petition alleges tbe death of Charles E. Patrick and that on tbe 22nd day of October, 1917, a paper writing purporting to be tbe last will and testament of tbe said Patrick, dated May 10, 1913, and two codicils dated, respectively, May 13, 1913, and April 20, 1915, were admitted to probate; that said paper writings are not the last will or the codicils of said Patrick. Plaintiff prays that an issue be made up as to whether such paper writings are tbe last will and codicils of said decedent.

[386]*386On December 10, 1919, a motion was filed to amend tbe petition by inserting such facts as would disclose that there was a third codicil to said will, dated August 11, 1915, but not mentioned in the petition. The will and codicils having been probated on the 22nd of October, 1917, more than a year had elapsed before the filing of the motion to amend the petition and counsel for defendant urged that under the provisions of Sections 10531 and 12087, G. C., limiting the time in which a contest of a will may be begun, the plaintiff can not amend her petition so as to raise an issue as to a codicil not mentioned in the petition.

The court overruled the motion on the ground that if it was necessary that the third codicil be mentioned in the petition before it could b'e attacked as invalid, the time in which such action might be .taken had expired, and that if such an attack might be made under the petition as filed, it would not be necessary to amend the petition so as to mention the third codicil.

Counsel now apply to the court to make up the issue, as directed by Section 12087, which provides ‘ ‘ an issue must be made up either by pleadings, or an order on the journal, whether or not the writing produced is the last will and codicil of the testator, which shall be tried by a jury.”

The will of the testator, with the three codicils appended, were all written on the same sheet of paper and were probated at the same time under the following order of the court:

“Whereupon, the court finds that the foregoing instruments of writing are the last will and testament and the codicils of said Ob arles E. Patrick, deceased. # * * It is therefore by the court ordered that said will and codicils be admitted to probate. ’ ’

The third codicil, which was not mentioned in the petition, and concerning which the controversy now arises, was dated on the 11th day of August, 1915, and is as follows, except the attestation

“1, Charles E. Patrick, do hereby declare this paper writing to be a codicil to my last will and testament bearing date of May [387]*38710th, 1913. I hereby revoke Item 7 of my said last will and testament, and hereby confirm and ratify my said last will and testament and codicils thereto, in all other respects.”

It is claimed by the defendant that the third codicil was a separate testamentary act of the testator, and that thereby he confirmed and ratified the will bearing date of May 10, 1913, and that said ratification made a new testamentary disposition of his estate as of the date of the codicil.

“A properly executed codicil, which is attached to a will, or which refers to it specifically as by its date and contents, acts as a republication of the will as of the date of the codicil.” Page on Wills, Sec. 307.

The position urged by counsel for defendant is that the plaintiff not having made an attack specifically upon the third codicil to the will, and such codicil having confirmed and ratified the will by proper designation, the will by such confirmation and ratification becomes a valid testamentary instrument, binding from the date of the probate, and that therefore even though the plaintiff successfully attack the will and the two codicils specifically mentioned in her petition, the wall and the two codicils must stand because ratified and confirmed by the subsequent codicil not mentioned specifically in the petition.

On the other hand, it is urged by counsel for plaintiff that in as much as the issue that must be submitted to the jury is “whether or not the -writing produced is the last will or codicil of the testator,” that the will and all the codicils attached thereto, may be attacked, even though one of the codicils be not specifically mentioned.

It must be conceded that a party -wishing to attack a testamentary instrument, would have the right under the statute, to at1 aek one or more of the codicils without involving the validity of the will itself, and it is urged that conversely, he may attack the will itself without attacking a codicil appended thereto.

It must also be conceded, even though an attack upon a will and some of its codicils be successfully made, that if there is a [388]*388subsequent codicil confirming and' ratifying tbe will, which is not successfully attacked that the valid codicil makes good the will which was successfully attacked.

If the will is republished • by the valid codicil, it is valid, no matter what defects may have originally existed in its execution. Page on Wills, Section 311.

It is first, of interest to determine the exact relation of a codicil to a will. Section 10502 of Chapter Two, relating to the execution and probate of wills, provides:

“In this title, the term ‘will’ includes codicils.”

However, this statutory definition is in a measure modified by Section 12079, in the Chapter relating to contests of wills, which provides:

“A person interested in a will or codicil admitted to probate,” etc.

These two sections indicate that as to the execution and probate of wills, the term “will” should include codicil, but that in the Chapter relating to contests, the two. may be regarded as separate testamentary dispositions.

Hitchcock, Judge, delivering the opinion of the court, in the case of Negley v. Gard, 20 Ohio, 315, says:

‘ ‘ In construing a will, to which are attached or added codicils, the whole is to be taken together as one instrument. The codicils constitute a part of the will.”

In the case of Collier v. Collier, 3 O. S., 269 Ranny, .J., at page 373, says:

“In endeavoring to elicit the intention of the testator, the will and codicils must be read and considered together” — citing Negley v. Gard, and quoting Chancellor Kent.

These rules are laid down in reference to construction of wills, and not to their contest.

In the will now before the court, the third codicil disposes of no estate, except as it refers back to the body of the will.

Section 12082 provides that an issue must be made up, wheth[389]*389er or not the writing produced is the last will or codicil of the testator. This section is discussed at large in the case of Dew v. Reed, 52 O. S., 519, wherein it is held that rules of pleading under the Code, when inconsistent with the statutory provisions relating to contests, are inapplicable; the action must be conducted in conformity with the special proceedings.

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Bluebook (online)
22 Ohio N.P. (n.s.) 385, 31 Ohio Dec. 319, 1920 Ohio Misc. LEXIS 14, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trull-v-patrick-ohctcomplclark-1920.