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Crocker-Citizens National Bank v. Crockett

Citations: 241 Cal. App. 2d 215; 50 Cal. Rptr. 358; 1966 Cal. App. LEXIS 1237Docket: Civ. No. 22690

Court: California Court of Appeal; March 30, 1966; California; State Appellate Court

Narrative Opinion Summary

In this case, beneficiaries under the will of Camille Ehrenfels contested the trial court's decree that satisfied bequests of Standard Oil Company stock with shares from Diversification Fund, Inc. The primary legal issue involved the classification of these bequests as specific or general legacies, with appellants arguing for a general classification that would entitle them to the original shares or their cash equivalent. The trial court concluded that the bequests were specific, based on the language of the will and extrinsic evidence of the decedent's intent. The court held that the exchange of Standard Oil stock for Diversification Fund shares during the decedent's incompetency did not adempt the specific bequests, as the stock could be traced back to the original shares. The appellate court upheld this decision, finding substantial evidence supporting the trial court's interpretation of the will. The court's ruling emphasized the importance of the testator's intent and the adequacy of the extrinsic evidence presented. The appellants' petition for a Supreme Court hearing was denied, and the specific bequests were to be fulfilled with adjusted shares of Diversification Fund, Inc. stock. All statutory references were to the Probate Code.

Legal Issues Addressed

Ademption of Specific Bequests

Application: The guardian's exchange of Standard Oil stock for Diversification Fund, Inc. stock during the testator's incompetency did not adempt the specific bequests, as the stock could be traced back to the original shares.

Reasoning: In the Mason case, it was established that without evidence of the testator's intent for ademption, a guardian's sale of specifically bequeathed property during the testator's incompetence does not nullify the specific bequest.

Extrinsic Evidence in Will Interpretation

Application: Extrinsic evidence demonstrated the testator's strong preference for Standard Oil stock, supporting the conclusion that the bequests were specific.

Reasoning: The trial court received extrinsic evidence regarding the testator's strong connection to Standard Oil, influenced by her husband's long employment there and financial advice she received about diversifying her portfolio, which she chose to ignore in favor of retaining the stock.

Specific vs. General Legacies

Application: The court determined that the bequests of Standard Oil stock were specific legacies, intended to be fulfilled with exact shares from the decedent's holdings at the time of the will's execution.

Reasoning: The trial court concluded the bequests were specific and not adeemed, deciding that the stock legatees should receive equivalent shares of Diversification Fund, Inc. stock.

Testator's Intent in Bequest Classification

Application: The testator's intent was critical in classifying the bequests as specific, with the will's language and extrinsic evidence supporting this interpretation.

Reasoning: The testator's intent is the primary factor in distinguishing between specific and general legacies, as outlined in section 163, which emphasizes that the testator's expressed intention governs the interpretation of legacies.