HomeMy WebLinkAbout04-25-78 (2)
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IN RE:
ESTATE OF
In the Court o~ Co~on Pleas of
Cumberland County, Pennsylvania
I JACOB HENRY MILLER,
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An Alleged Incompetent
Orphans' Court Division
No. 121 Orhapns' 1978
MEMORANDUM ON BEHALF OF
JA,COB HENRY MILLER, SR.
I. FACTS
Jacob H. Miller, Sr. resides at R. D. 4, Mechanicsburg, Pennsylvania
on a 167 acre farm where he has ~armed the property since the mid 1940's.
Mr. Miller and his wife had two children, Harold A. Miller and Jacob H.
Miller, Jr. Mrs. Miller, the wife, passed away several years ago.
Mr. Miller up to the present time continues to do some farming at
his farm and is currently actively managing his own af~airs. In October
of 1977 the sons had Mr. Miller hospitalized at the Holy Spirit Hospital.
A~ter receiving treatment, the sons expressed a desire that Mr. Miller
be taken to a nursing home rather than his own home. He was subsequently
taken to the Camp Hill Nursing Home. Mr. Miller became upset when he was
hospitalized at the Holy Spirit Hospital and even more upset when he was
placed in the Camp Hill Nursing Home. It had been his desire throughout
to return to his farm and to continue to manage his own affairs.
While Mr. Miller was in the Holy Spirit Hospital, his sons apparently
had him sign a power of attorney to Jacob H. Miller, Jr. to manage the
affairs of his father. When Mr. Miller returned home, he found money and
other items missing from his home and upon learning of the power of
attorney, he immediately had it revoked.
Several months have passed and Mr. Miller has competently managed
his own affairs and run his farm. He has become upset with the action
of his sons who returned some of the money they had taken while he was in
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For reasons known only to themselves, Mr. Miller's sons have now
petitioned the Court to have him declared incompetent. Numerous witnesses,
including an expert medical witness, will testify on behalf of Mr. Miller
and will testify as to his competency and his continued ability to manage
his own affairs.
II. LEGAL PRINCIPLES
1. Jacob H. Miller, Sr. is presumed competent and
the burden of proving otherwise rests with the
petitioners. ~,Myer's Estate, 395 Pa. 459 (1959).
Jacob H. Miller, Sr. is presumed competent. As noted by the
Pennsylvania Supreme Court in construing previous but similar statutory
language:
. . . the proof of mental incapacity must clearly meet
the terms of the law before any persons should be
deprived, under it, of the right to manage his or her
own property. The presuDlption of sanity and mental
capacity cannot be lightly overthrown.
McGuigan Estate, 349 Pa. 581 at 589 (1944).
In Estate of Porter, 463 Pa. 411 (1975), the Supreme Court discussed
the burden of proof which would apply to the instant case. In the Porter
case, the Supreme Court reversed a lower court which had refused to order
that the appellant was competent after a previous determination of feeb1e-
mindedness.l The court also discussed the standard of proof applicable
to the petition in the present case. The court noted:
Proof of mental incompetency must possess such
strength and clarity as to lead incontestably to
but one conclusion, to wit, that respondent is
mentally incompetent. A finding of mental
incompetency is not to be sustained simply if there
is any evidence of such incompetency but only where
the evidence is preponderating and points unerringly
lThe case involved an estate valued at about $250.000.
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to mental incompetency. If the finding of mental
incompetency i~ not ba~ed on evidence of ~uch
quality then ~uch finding amount~ to an abuse of
judicial di~cretion.
463 Pa. at 416 citing Myer'~ E~tate, 395 Pa. 459 (1959).
The te~timony will reveal that the burden of proof ha~ not been met
by the pet1tioner~ and mu~t be dismissed.
2. Testimony of lay witnesses is admissible on
the issue of competency. See, Owens Appeal,
167 Pa. Super. 10 (1950). ---
Jacob H. Miller, Sr. will present numerous lay witnesses who will
unequivocally indicate that Jacob H. Miller, Sr. is fully competent to handle
his own affairs. Many of these witnesses are totally impartial and stand
nothing to gain from their testimony. The witnesses will include
businessmen, a lawyer, a real estate agent, friends and neighbors. Their
conclusions will be supported by a psychiatrist and by Jacob H. Miller Sr.
In Owens Appeal, 167 Pa. Super. 10 (1950), the Superior Court
disregarded the testimony of a physician and reversed a lower court which
had declared the appellant to be incompetent. The Superior Court noted:
It i~ a serious thing to deprive any person of the
control of their own property or of their right to
dispose of it by will. This right will be judicially
taken away from a person only after preponderating
proof of his lack of mental capacity to manage his
own busine~s affairs. (Emphasis added.)
A lay witness may testify to the mental condition of
a person when the facts upon which the opinion is based
are stated. Rouch v. Zehring, 59 Pa. 74; Dickinson
v. Dickinson, 61 Pa. 401.
167 Pa. Super. 10 at 14, 17.
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3. The testimony of the petitione. and other
should be scrutinized carefully by the court.
Denner v. Beye., 352 Pa. 386 (1945).
relatives
~,
A court should scrutinize the evidence carefully and determine the
true motives of the petitioners. It is believed that the court will
conclude:
The record gives the impression that the motive for
the petition was not so much to conserve the
respondent's property as to channel its inheritance
to the next of kin.
Denner v. Beyer, 352 Pa. 386 (1945); ~ also, Axe Estate, 34 D & C 2d 625
(1964) .
4. The testimony will indicate that the petitioners
have failed in their burden of proof. In Re Porter's
Estate, 463 Pa. 411 (1975).
The petition filed contains absolutely no facts to support its
conclusiona'Y allegation.2 The evidence, however, will reveal that
Jacob H. Mille., Sr., age 85, is fully competent to handle his own affairs.
The only possible suggestions to the contrary come from persons
who have an interest in the outcome of the case. Unfortunately, the sons
of Jacob H. Miller, Sr. took it upon themselves to admit Jacob H. Miller Sr.
to the Holy Spirit Hospital on or about October 15, 1977. He was admitted
with "shortness of breath, bad cold syndrome, probable pneumonitis".
He became very upset when he realized that it was his family's plan
to transfer him to a nursing home rather than permit him to go home. He
2The petition is based on the conclusion that the alleged incompetent
is unable to manage his property because of infirmities of old and physical
illness. It should be noted that physical illness is not even included
as a reason for incompetency in the statute. See, 20 Pa. Stat. Ann. ~550l.
See Owens Appeal, 167 Pa. Super. 10 (1950). -
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was eventually transferred to the Camp Hill Nursing Home. He then secured
his release fr~ the nursing home and returned to his farm.
H~ learned that while he was in the hospital, he apparently signed
a power of attorney giving 3acob H. Miller, Jr., power of attorney. This
power of attorney was dated October 26, 1977 and was apparently signed
at the Holy Spirit Hospital.3 Upon learning of the existence of the docu~ent,
he i~ediately had it revoked.
The power of attorney was apparently drawn up at the request of
Jacob H. Miller, Jr. and witnessed by Harold A. Miller, the other son. The
existence of the power of attorney certainly indicates that the very persons
who now atte~pt to show incompetency, only several ~onths ago had Jacob H.
Miller Sr. sign a legal document.
Jacob H. Miller Sr. acted properly in revoking the power of attorney
after leaving the Camp Hill Nursing Home. While Jacob H. Miller, 3r. had
access to the accounts, he cashed in a savings certificate which lost
several hundred dollars for Mr. Miller. When Jacob H. Miller Sr. returned
home from the nursing home, he also found things missing from the home
including his legal documents.
In Denner v. Beyer, 352 Pa. 386 (1945), the court indicated that a
revocation of a power of attorney under si~lar circumstances was proper.
The court noted at page 397:
Her revocation of a power of attorney given her
brother-in-law, from whose home she had been eyicted,
and the ~ecution of a power of attorney in fayor of
her trusted friend, who was her husband's counsin,
was likewise reasonably called for under the circumstances.
Instead of e~hibiting the vacillation characteristic of
weakness of mind, she e~hibited the decision
characteristic of strength of mind.
30n that date, the medical records reveal that Mr. Miller was
extremely upset and under medication.
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The petitioners apparently realize that their ~ather is extremely
upset with his sons for atte~pting to keep him in a nursing home away ~rom
his farm. Apparently they have attempted to show that because Jacob H.
Miller, Sr. is suspicious of them, this proves incompetency. Those
suspicions are well founded and do not suggest incompetence. In determining
that a person was competent the court in a similar case noted:
On the witness stand Aaron D. Weaver testified lucidly.
He knew his relatives, his property. Although
eighty-five years of age, he was of clear intellect.
He seemed suspicious and is displeased with his son,
and the other members of the family, and does not
trust them. Part of this distruct, however, comes
from the fact that a petition to declare him feeble
minded has been lodged by the son.
In Re Weaver, 3 Lyc. 191 (1952).
It is doubtful that the petitioners will produce expert medical
testimony to support their position. If, however, the petitioner uses the
doctor who treated Jacob H. Miller, Sr. in the hospital, his testimony
should be disregarded or treated lightly.4 See Owens Appeal, 167 Pa. Super.
10 (1950); Ex parte v. Gunn, 65 Mont. L.R. 167 (1949).
The only other factor which the petitioners may raise is the fact
that a sale of real estate of Jacob H. Miller, Sr.'s farm is imminent.
That sale, however, was the rpsult o~ careful negotiations in which Jacob H.
Miller Sr. participated in with total competence. An attorney, a real
estate salesman, and others will support that. The evidence will also show
the reason for the sale and fairness of the bargain. Cf., In Re Weaver,
3 Lyc. 191 (1952).
The petitioners seem also upset that Jacob H. Miller, Sr. has a
housekeeper who is taking care of him. The housekeeper's employment, however,
is exactly what was suggested by the nursing home.
SL"TI!:'O'O
4Dr. Sullivan's notes on the hospital chart do not suggest incompetenc
Several weeks ago, in fact, Dr. Sullivan's office contacted Mr. Miller at
home in an attempt to get Mr. Miller into his office "to talk" about the
court case. When Mr. Miller inquired "why?", no further contact was pursued
by the doctor's o~~ice. When the attorney for Mr. Miller tried to find out w y
the doctor called, the doctor offered no explanation.
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The biggest fear which the petitioners apparently have is the fact
that they might lose their inheritance because of their attempts to keep
Jacob H. Miller Sr. in a nursing home against his will. The court, however,
should not prevent Jacob H. Miller, Sr. from handling his affairs. If
the father wants to change a Will because of what his sons have done to him,
he has that right.
As noted in Estate of Porter, 463 Pa. 411 at 415 (1975):
A ~n ~y do what he pleases with his personal estate
during his life. He may even beggar himself and his
family if he chooses to commit such an act of folly.
When he dies, and then only, do the rights of his
heirs attach to his estate.
In Axe Estate, 34 D & C 2d 625 at 635 (1964), the court likewise
noted:
The act is for the protection of the respondent and
is not intended to prevent the owner of an estate
from doing with his own what he pleases in order
that his children may inherit a greater amount.
Respectfully submitted,
ncke, Esquire
for Jacob H. Miller, Sr.