Wheeler Estate

31 Pa. D. & C.2d 145, 1963 Pa. Dist. & Cnty. Dec. LEXIS 310
CourtPennsylvania Orphans' Court, Washington County
DecidedMay 23, 1963
Docketno. 49 of 1962
StatusPublished

This text of 31 Pa. D. & C.2d 145 (Wheeler Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Washington County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wheeler Estate, 31 Pa. D. & C.2d 145, 1963 Pa. Dist. & Cnty. Dec. LEXIS 310 (Pa. Super. Ct. 1963).

Opinion

Marino, P. J.,

Novella Henderson presented her petition for the Family Exemption in the estate of Samuel A. Wheeler, deceased. The facts are not in dispute. The decedent, during the last two years of his life, was domiciled in the home of petitioner. She attended to his needs and nursed him until the time of his death on August 12,1961. Undoubtedly she was a member of the same household as decedent. But she was not a child of the decedent; she was a stepdaughter. That fact raises the only issue before the court in this proceeding. Are stepchildren included in the classification of those who may be entitled to the family exemption under provisions of the applicable section of the Fiduciaries Act of April 18, 1949, P. L. 512, as amended?

We make reference to section 211 of the Fiduciaries Act, 20 PS §320.211, as amended, which now provides: “The spouse of any decedent dying domiciled in the Commonwealth, and if there be no spouse, or if he has forfeited his rights, then such children as are members of the same household as the decedent, may retain or claim as an exemption, either real or personal property, or both, not theretofore sold by the personal representative, to the value of one thousand dollars

Section 211 of the Fiduciaries Act of 1949 is based on section 12 (a) of the Act of June 7,1917, P. L. 447, and differs from it only in a few particulars. The right of exemption was extended to a surviving husband, and the children must form a part of decedent’s “household” rather than “family”. The 1917 act was a codification or general revision of the then existing law, [147]*147and its provisions as to exemption differed little from section 5 of the Act of April 14,1851, P. L. 618. Hence, the decisions and authorities construing the earlier statutes should be considered persuasive in the interpretation of the section of the present act now under consideration.

Petitioner’s counsel states that he has made an exhaustive search of our state authorities as well as those of other states, and that he has been unable to find any reported case wherein the matter of stepchildren has been examined or considered in connection with the term “children’s exemption”. This court has been similarly unsuccessful, as far as Pennsylvania precedent is concerned. The case is undoubtedly one of first impression in the Commonwealth.

The question was recently raised in this court, but left undecided, in the case of Griffith Estate, 41 Wash. 98, 11 Fiduc. Rep. 182, where the stepdaughter did not qualify as a member of decedent’s household. We there said: “Whether a stepchild would qualify we are not constrained to decide, as it is admitted that petitioner was not a member of the same household as the decedent, and both requirements must concur.” In the literally hundreds of cases examined by counsel and the court, this is the sole reference made to the possibility that stepchildren might possibly be considered as within the purview of the statute.

The report of the Joint State Government Commission is completely silent on the interpretation of the term “children” as used in this section of the act. Accountant urges that this is an indication that the term must receive a strict construction, especially when there is available no prior court construction of the term over a period of more than a. century. But we believe the mere fact that the question has never been raised, to our knowledge, is no indication, ipso facto, of the weakness of the basic idea or substance of the [148]*148petitioner’s position. There is all the more reason for a thorough consideration of these contentions when no precedent is available.

Petitioner contends that there is some analogy between the use and meaning of the word “children” as used in the exemption statute and the definition of same as used in the Inheritance and Estate Tax Act of 1961, 72 PS §2485-102(3), (13), which latter reads:

(3) “Children includes adopted children, stepchildren, illegitimate children of the mother . . .

(13) ‘Lineal descendants’ includes children and their descendants, adopted descendants, and their descendants, stepchildren, . . .”

It is contended that these statutes are in pari materia. The Statutory Construction Act of May 28,1937, P. L. 1019, sec. 62, 46 PS §562, provides: “Laws or parts of laws are in pari materia when they relate to the same persons or things or to the same class of persons or things.

“Laws in pari materia shall be construed together, if possible, as one law.”

It is well recognized that statutes in pari materia should be considered concurrently whenever possible, and if they can be made to stand together, effect should be given to both as far as possible: Kelly v. City of Philadelphia, 382 Pa. 459, 477; First National Bank of Millville v. Horwatt, 192 Pa. Superior Ct. 581, 586; Nyce v. Commissioners, 319 Pa. 353, 358, 359.

However, the rule that statutes which are in pari materia should be read together is applicable only if the words of a statute are ambiguous: McFarland Estate 377 Pa. 290, 296. In 82 C. J. S., Statutes, § 366b, it is stated: “. . . It must not be overlooked that the rule requiring statutes in pari materia to be construed together is only a rule of construction to be [149]*149applied as an aid in determining the meaning of a doubtful statute, and that it cannot be invoked where the language of a statute is clear and unambiguous.”

It is urged that the term “children”, as used in the exemption statute, is ambiguous, since in common parlance it is used to designate adopted children, foster children, stepchildren, illegitimate children, children to whom the parent stood in loco parentis, etc. The fact that legislature saw fit to particularly define the word “children” in various other statutes is heavily relied upon as a noteworthy circumstance pointing to ambiguity. In addition to the Inheritance and Estate Tax Act of 1961, hereinabove referred to, there is a Workmen’s Compensation Act of June 2, 1915, P. L. 736, as amended, 77 PS §562, which states “. . .the term ‘child’ and ‘children’ shall include stepchildren, adopted children and children to whom he, the parent, stood in loco parentis, . . .”.

On a national scale, Congress. enacted' the Social Security Act and made somewhat similar- disposition of the problem of defining children to include adopted children, and stepchildren as well, if they were such for twelve months immediately preceding the month in which the individual died: 42 U. S. C. A. §416(e), after August 28,1950, amendment.

We can deduce no proper analogy between treatment of the term “child or children” as defined and used in various other statutes, such as those adverted to, unless such statutes can be found to be in pari materia with the Fiduciaries Act or the section of such act dealing with the Family Exemption. However, the subject matter of the Inheritance and Estate Tax Act of 1961 is purely and exclusively that of taxation as related to inheritances and transfers of property in contemplation of death. It is further pointed out that section 613 of the act deals with “Family Exemption”. [150]*150But it is to be noted that this section is a part of Article VI, entitled “Deductions”, and said section 613 simply provides: “Family Exemption — The family exemption shall be deductible.” There is no attempt to redefine what constitutes the family exemption, who is entitled thereto, or any explanation of its terms.

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Related

Kelly v. Philadelphia
115 A.2d 238 (Supreme Court of Pennsylvania, 1955)
McFarland Estate
105 A.2d 92 (Supreme Court of Pennsylvania, 1954)
1ST NAT. BK. of MILLVILLE v. Horwatt
162 A.2d 60 (Superior Court of Pennsylvania, 1960)
Nyce v. Board of Commissioners
179 A. 584 (Supreme Court of Pennsylvania, 1935)
Arnout's Estate
128 A. 661 (Supreme Court of Pennsylvania, 1925)
Warner v. Miner
82 P. 1033 (Washington Supreme Court, 1905)
Nevins's Appeal
47 Pa. 230 (Supreme Court of Pennsylvania, 1864)
Johnson's Appeal
88 Pa. 346 (Supreme Court of Pennsylvania, 1879)
Estate of Rowan
19 A. 82 (Supreme Court of Pennsylvania, 1890)
Hildebrand's Estate
104 A. 866 (Supreme Court of Pennsylvania, 1918)
Boyle v. Dealer's Transport Co.
132 A.2d 709 (Superior Court of Pennsylvania, 1957)
Robinson's Estate
35 Pa. Super. 192 (Superior Court of Pennsylvania, 1908)
Mayers v. Ewing
102 F. Supp. 201 (E.D. Pennsylvania, 1952)

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Bluebook (online)
31 Pa. D. & C.2d 145, 1963 Pa. Dist. & Cnty. Dec. LEXIS 310, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wheeler-estate-paorphctwashin-1963.