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Gorn v. Temple B'Nai Israel

Citations: 526 So. 2d 118; 13 Fla. L. Weekly 1033; 1988 Fla. App. LEXIS 1687; 1988 WL 39147Docket: No. 87-2427

Court: District Court of Appeal of Florida; April 27, 1988; Florida; State Appellate Court

Narrative Opinion Summary

A codicil executed within six months of the testator's death converted potential gifts to charitable entities into actual bequests. However, under section 732.803(1) of the Florida Statutes (1985), such gifts are voidable when made within this timeframe. The trial court's intention to fulfill the testator's wishes cannot override this statutory provision. Consequently, the appellate court reversed and vacated the trial court's order and remanded the case for further proceedings. Judges Danahy, Campbell, and Frank concurred with the decision.

Legal Issues Addressed

Appellate Review and Remand

Application: The appellate court vacated the trial court's order and remanded the case, highlighting the appellate court's authority to reverse lower court decisions that misapply statutory law.

Reasoning: Consequently, the appellate court reversed and vacated the trial court's order and remanded the case for further proceedings.

Judicial Authority versus Statutory Provisions

Application: The appellate court held that a trial court cannot fulfill the testator's wishes if doing so contravenes statutory provisions, emphasizing the supremacy of statutory law over judicial intentions.

Reasoning: The trial court's intention to fulfill the testator's wishes cannot override this statutory provision.

Voidable Bequests to Charitable Entities Under Florida Statutes

Application: The court determined that bequests to charitable entities made within six months of the testator's death are voidable under section 732.803(1) of the Florida Statutes, regardless of the testator's intentions.

Reasoning: However, under section 732.803(1) of the Florida Statutes (1985), such gifts are voidable when made within this timeframe.