Van Kirk v. Curry

4 Pa. D. & C. 299, 1923 Pa. Dist. & Cnty. Dec. LEXIS 341

This text of 4 Pa. D. & C. 299 (Van Kirk v. Curry) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Washington County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Van Kirk v. Curry, 4 Pa. D. & C. 299, 1923 Pa. Dist. & Cnty. Dec. LEXIS 341 (Pa. Super. Ct. 1923).

Opinion

Cummins, J.,

— Plaintiff has filed a: bill, praying for the partition of a certain parcel of ground, in which bill it is averred that plaintiff has purchased a life estate; that the remainder therein had previously vested jointly in himself and the defendants named in the bill; and that the interest of the plaintiff as remainderman is an undivided 13/24th interest. To this bill a demurrer was filed denying the jurisdiction of the court.

The plaintiff being already the owner of an undivided 13/24th interest of the remainder in fee, and having purchased the entire life estate, it may very logically be contended that a merger would thereby be effected of his undivided interest in remainder with an equal interest in the life estate, so that he would now hold an undivided 13/24ths interest in fee simple and in possession, and a life estate in the residue: Clark v. Parsons, 69 N. H. 147, 39 Atl. Repr. 898; Clark v. Clark, 56 N. H. 105, 113; McLaughlin v. McLaughlin, 80 Md. 115, 30 Atl. Repr. 607; 4 Kent’s Com., 100, 101; Gaddes v. Bank (R. I.), 80 Atl. Repr. 415.

Where such interests in real estate are thus vested in one person, thereby giving him exclusive possession of the whole, do our Courts of Common Pleas, sitting in equity, have jurisdiction to make partition?

The Act of Feb. 14, 1857, P. L. 39, was the first general act conferring equity jurisdiction on our Courts of Common Pleas in partition proceedings. And now, by the Act of July 7, 1885, P. L. 257, our Courts of Common Pleas on the equity side have jurisdiction in all cases of partition: Hanna v. Clark, 189 Pa. 321; Mercur v. Jackson, 3 Pa. C. C. Reps. 387; Sheridan v. Sheridan, 136 Pa. 14.

[300]*300The purpose of all of the earlier acts by which jurisdiction in proceedings of partition was conferred upon our Courts of Common Pleas was not to enlarge the scope of the common law writ, but merely to create jurisdiction in a new forum and to regulate the procedure therein: Seiders v. Giles et al., 141 Pa. 93; Doyle v. Brundred, 189 Pa. 113.

At common law an action of partition was not only an action real (Power v. Power, 7 Watts, 205; Miller on Partition, 11), but was likewise a possessory action, “such wherein the right of possession only, and not that of property, is contested:” 2 Blackstone’s Comm., 198; Ross v. Pleasants, 19 Pa. 157, 168; Holmes v. Fulton, 193 Pa. 270, 272. The purpose of the writ was to make division of the possession. Therefore, there had to be a joint holding of the possession, a concurrent holding: Law v. Patterson, 1 W. & S. 184, 193. It followed, therefore, that one who had been ousted, not being in possession, could not sue out such writ (1 Thomas’s Coke, 543; Law v. Patterson, 1 W. & S. 184; Galbreath v. Galbreath, 5 Watts, 146; McMahan v. McMahan, 13 Pa. 376); nor was a remainderman entitled to partition (Deshong’s Estate, 6 Del. Co. Reps. 519; Stevenson’s Estate, 50 Pitts. L. J. 419; Smith’s Estate, 2 Del. Co. Reps. 423; Seiders v. Giles et al., 141 Pa. 93; Holmes v. Fulton, 193 Pa. 270, 272), or one who was in sole possession, as, e. g., a life-tenant in the whole (Seiders v. Giles et al., 141 Pa. 93; Kerner’s Estate, 12 Dist. R. 718), or where one, as in the case at bar, was in exclusive possession, being possessed of a part in fee and having the life estate in the residue: Hodgkinson’s Petition, 12 Pickering’s Rep. (Mass.) 374. The plaintiff, therefore, is not entitled to partition, and this court is without jurisdiction to decree partition, unless the scope of this remedy has been enlarged by legislation so as to include such cases.

Counsel for plaintiff claims that this result has been effected by the Act of April 11, 1835, § 1, P. L. 199, which reads as follows: “Writs of partition may be sued by parties interested in real estate, . . . notwithstanding there may be a life estate in part or parts of the property, with remainders over in fee: Provided, that all persons interested shall be made parties, and . . . that those in remainder shall have the right to take such part as shall be awarded to them, on giving sufficient security . . . for the payment of the annual interest of such part to the tenant for life, unless it shall appear to the court that such tenant for life is entitled to the exclusive possession of any part of the premises, ... in which case the proceedings shall not interfere with the right of possession of such tenant without his consent, but may be had subject to such possession,” etc.

This act, together with the Supplemental Acts of June 3, 1840, P. L. 593, and April 5, 1842, P. L. 234, was before the Supreme Court in the case of Seiders v. Giles et al., 141 Pa. 93, in which case it was held that a tenant for life in all of the real estate involved in a partition proceeding, entitled to and in exclusive possession, could not maintain a proceeding of partition against the remaindermen. In construing these acts, Endlich, J., in his opinion, which was adopted by the Supreme Court, held first, that, with reference to the parties entitled to sue, the term “interested” was not used “in its ordinary or technical sense,” but merely “as. nomen generalissimum, to cover all such classes of persons, in respect to their estates, as were under the existing law in a situation to become parties to a suit for partition except for the obstacle of intervening life estates (in part or parts of the property), which obstacle this statute removed” (pages 98 and 99); and, second, that the act did not destroy the basic and fundamental principle underlying all proceed[301]*301ings in partition; that there must still be a joint or concurrent possession (pages 99, 101 and 102), and that to hold otherwise would “do violence to the essential character, design and incidents of the proceeding [itself] known as partition:” Page 102.

The case of Holmes v. Fulton, 193 Pa. 270, is distinguished from Seiders v. Giles et al., 141 Pa. 93, in that the plaintiff was a tenant for life only in a part of the property to be partitioned, and the same was true in the late case of McDonald v. McDonald, 256 Pa. 304, in which case Seiders v. Giles et al. is several times quoted.

If it be held that plaintiff’s undivided interest in remainder did not merge with an equal interest of his life estate, then he would not be entitled to partition, as the Act of April 11, 1835, by its express terms, only embraces cases where there are life estates in but part or parts of the real estate sought to be partitioned, and would bring the case squarely within the ruling of Seiders v. Giles et al., 141 Pa. 93; whereas, if it be held that there was a merger, then there would be no joint holding or concurrent holding, as plaintiff’s holding would then be wholly in possession, while defendants’ holding would be alone in remainder; but the fact that, under the Act of April 11, 1835, there must be at least a concurrent holding is clearly recognized: Seiders v. Giles et al., 141 Pa. 93, 100, 101 and 102. Whether there was or was not a merger, for all substantial purposes, only raises a distinction without a difference, for the owner of the fee can at best only possess for his life the conveyance to him and to his heirs and assigns. The plaintiff in this case, in either event, is in exclusive possession of the whole of the land, the possession of which he seeks to have divided.

In Wolfe’s Estate, 22 Pa. C. C. Reps.

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Related

McMahan v. McMahan
13 Pa. 376 (Supreme Court of Pennsylvania, 1850)
Ross v. Pleasants
19 Pa. 157 (Supreme Court of Pennsylvania, 1851)
Seiders v. Giles
21 A. 514 (Supreme Court of Pennsylvania, 1891)
Deshong v. Deshong
40 A. 402 (Supreme Court of Pennsylvania, 1898)
Doyle v. Brundred
41 A. 1107 (Supreme Court of Pennsylvania, 1899)
Hanna v. Clark
41 A. 981 (Supreme Court of Pennsylvania, 1899)
Holmes v. Fulton
44 A. 426 (Supreme Court of Pennsylvania, 1899)
McDonald v. McDonald
100 A. 867 (Supreme Court of Pennsylvania, 1917)
Galbreath v. Galbreath
5 Watts 146 (Supreme Court of Pennsylvania, 1836)
Power v. Power
7 Watts 205 (Supreme Court of Pennsylvania, 1838)
Law v. Patterson
1 Watts & Serg. 184 (Supreme Court of Pennsylvania, 1841)
Sheridan v. Sheridan
19 A. 1068 (Philadelphia County Court of Common Pleas, 1890)
McLaughlin v. McLaughlin
30 A. 607 (Court of Appeals of Maryland, 1894)

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Bluebook (online)
4 Pa. D. & C. 299, 1923 Pa. Dist. & Cnty. Dec. LEXIS 341, Counsel Stack Legal Research, https://law.counselstack.com/opinion/van-kirk-v-curry-pactcomplwashin-1923.