Wadsworth v. Purdy

21 Ohio C.C. Dec. 110
CourtOhio Circuit Courts
DecidedJune 30, 1908
StatusPublished

This text of 21 Ohio C.C. Dec. 110 (Wadsworth v. Purdy) is published on Counsel Stack Legal Research, covering Ohio Circuit Courts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wadsworth v. Purdy, 21 Ohio C.C. Dec. 110 (Ohio Super. Ct. 1908).

Opinion

DONAHUE, J.

This proceeding in error is brought to reverse the judgment of the common pleas court of this county in an action in said court, wherein Anna D. Wadsworth sought to set aside the will of H. W. Baird, deceased, claiming, first, that said will was not properly executed, second, that the testator had not mental capacity to make a will.

Upon the trial of the cause in common pleas court the jury returned a verdict sustaining the will, and judgment was rendered accordingly. A motion for new trial was filed and the samé was overruled. The principal errors now urged upon the attention of this court are, first, misconduct of counsel in the argument of the cause; second, error in the charge of the court; third, that the verdict of the jury was not sustained by sufficient evidence.

First, as to misconduct, of counsel. It appears that in the argument of this cause one of the counsel for defendants was permitted to, and did, argue to the jury, in effect, that the same evidence' now before the jury was offered to Judge Hadden of the probate court, and that he, with all his experience in such matters, had sustained the will and admitted it to probate, and that it would be presumptuous in the jury to hold different from Judge Hadden. This all appears in the bill of exceptions, but it is also certified that this matter was not called to the attention of the court by means of affidavit or otherwise upon the motion for new trial. We think that is not important. There are a great many other errors complained of in this bill of exceptions that were not brought to the attention of the court upon the motion for new trial by affidavit, deposition or oral testimony. The trial court is presumed to know what occurred at the trial of this cause as it now appears by the bill of exceptions. In fact he certifies this'bill of exceptions to be a'true bill, and we think the matter was clearly before him upon the motion for new trial, as much as was the admission of evidence or errors in the charge of the court, or any other matters or things excepted to by counsel for plaintiff in error upon the trial of said cause, and it is now before this court for review. We are unanimously of the opinion that this argument was improper and prejudicial to the rights of the plaintiff in error.

The method provided by statute (Secs. 5858-5866 Rev. Stat.) for contesting a will is exclusive, Mosier v. Harmon, 29 Ohio St. 220, and the statute providing for the probating of a will does not provide that the contest may be had touching its admission to probate.

Section 5926 Rev. Stat. provides,

“The said court shall cause the witnesses to such will, and such [112]*112other witnesses as any person interested in having the same admitted to probate, may desire, to come before such court; and said witnesses shall be. examined in open court, and their testimony reduced to writing, and filed.”

From this statute it clearly appears that only witnesses to the will and such other witnesses as may be offered by parties interested in having the will admitted to probate, can be heard. Parties interested in not having the will admitted to probate have no right to call witnesses. It is practically to all intents and purposes a proceeding ex parte in its nature.

In the case of Bolles v. Harris, 34 Ohio St. 38, at page 41, Judge White, speaking for the Supreme Court, says:

“The jurisdiction exercised in all such cases by the court and jury is virtually that of a court of probate, charged with the duty of finally establishing or rejecting the will. The proceeding to admit the will to probate in the first instance, is in its nature ex parte; the proceeding by contest is a suit inter partes.”

Citing in support thereof, Mears v. Mears, 15 Ohio St. 90; Converse v. Starr, 23 Ohio St. 498.

So that what Judge Hadden had done with this will was of no importance, except that by the force of the statute, it became prima facie evidence of the validity of this will, and cast the burden upon the contestors to show its invalidity. It is true that in this particular case it so happens that the same evidence is used in the common pleas court, touching the execution of the will, that was heard by Judge Hadden, and if there would be any excuse in any case for this argument, it would be this ease, but we think that because the action is ex parte, and because the judgment of that court covered all the questions touching the validity of this will, as well as its proper execution, it is unfair to say that the jury should have the right to consider what Judge Hadden had done touching the same. The effect of that judgment was simply to make a prima facie case in favor of the will, but upon this contest, the case, except for that, is heard de novo, and the jury ought not to be influenced by the action of Judge Hadden in the case, especially when his judgment was rendered in an ex parte proceeding, where counsel, perhaps, were not present, and if present, had no absolute right to be heard; and Judge Hadden’s judgment upon this case made in the common pleas court where counsel for all parties, had full right to be heard, and were heard, might have been entirely different. It was the duty of the common pleas court to interfere when its attention was called to this argument and to instruct that the judgment of the [113]*113probate court had no other or further effect than to cast the burden upon contestors. The court, by permitting this argument, in effect, said to the jury,

“You have a right to consider Judge Hadden’s action as authority in this particular case, and if a man of his experience and learning should hold this will upon this same evidence to have been properly executed and admitted to probate as a last will and testament, you should consider his action in connection with the evidence offered in determining what you ought to do in this case.”

We, therefore, think the argument of counsel in this respect was improper and that the court erred to the prejudice of plaintiff in overruling the objections of plaintiff in error’s counsel to the same, and in not then and there correcting in the mind of the jury any false impressions it may have received by reason of such argument.

The next error seriously urged upon this court is, as to the charge of the court, and particularly as to this language:

“If, therefore, you believe from the evidence that when Mr. Baird ¿xecuted the papers in dispute he had capacity enough to attend to his ordinary business, and to know and understand the business he yas engaged in, then he had the right and the capacity to make such a will, and you should find that the papers in dispute are his will.”

We do not think this is the correct definition of testamentary capacity, but whether it is prejudicial or not to plaintiff in error is a much more serious question. A person may lack in capacity for the transaction of ordinary business and lack in contractual capacity, and yet many have testamentary capacity. Mental capacity to make a will is said to exist where a testator has an understanding of the nature of the business in which he is engaged, a recollection of the property he means to dispose of, the persons who have a claim upon his bounty, and the manner in which it is to be distributed.

In 11 Am. & Eng. Enc. Wills 151, cited by counsel for plaintiff in error, we find this definition:

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Related

Will of Smith
8 N.W. 616 (Wisconsin Supreme Court, 1881)
Kimball v. Adams
9 N.W. 665 (Wisconsin Supreme Court, 1881)
Mosier v. Harmon
29 Ohio St. 220 (Ohio Supreme Court, 1876)
Otto v. Doty
15 N.W. 578 (Supreme Court of Iowa, 1883)
Rice v. Rice
19 N.W. 132 (Michigan Supreme Court, 1884)

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Bluebook (online)
21 Ohio C.C. Dec. 110, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wadsworth-v-purdy-ohiocirct-1908.