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90 Neb. 591

Brown v. Webster

Nebraska Supreme Court

Decided January 3, 1912

Nebraska Supreme Court · decided 1912-01-03

<p>1. Wills: Reciprocal Wills: Parol Contract Inter Vitos. Where a husband, and wife, possessed of separate estates, orally agree that upon the predecease of either the survivor shall thereupon become the owner of all of the estate, both real and personal, of such decedent, and at the same time, and in pursuance of,, and for the expressed purpose of providing a proper method of carrying such agreement into effect, simultaneously execute reciprocal wills, in each of which the other spouse is made, sole devisee and legatee, held that the oral agreement and the execution of the wills constitute a single transaction, that each is an integral part of one contract, and that such contract cannot be said to rest entirely in parol.</p> <p>2.--: -: -: Consideration. And, in such a case, the contract of each is a sufficient consideration for the contract of the other.</p> <p>3.-: -: -: Performance. And the continued reliance by plaintiff upon the contract, by permitting her will executed as a part thereof to remain in the family safe, unchanged and unrevoked, during the entire lifetime of the deceased, constituted full performance by her of the terms of the contract.</p> <p>4. -: -: Revocation. And the wills, executed as a part of such contract, in equity, are not ambulatory, and may not be revoked by either party to such contract so long as the other party continues to perform the contract on his or her part.</p> <p>5. -: -: Parol Contract Inter Vivos: Specific Performance. And where either party to such a contract commits a breach of the same by subsequently executing another will, devising and bequeathing his estate contrary to the terms of such contract, and dies, the survivor, upon proof of a continued performance thereof, in good faith, on his or her part, is entitled to a specific performance of the contract, as against the heirs, devisees, legatees, and executors of the decedent.</p> <p>6. Pleading. The petition, set out in the opinion, examined, and held *' sufficient.</p>

Good law ✅— No negative treatment on recordhow we know

Reversed · Decided 1912-01-03

How this case has been cited

Cited by 33 later decisions — most recently April 2009 · most notably Curry v. Cotton (1934), Kirk v. Beard (1961)

1 district · 31 state decisions — followed in 15 states

701912192019301940195019601970198019902000decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

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Root, J.

¶1I concur in the majority opinion, in so far as it reverses the judgment of the district court and remands the cause for further proceedings, but I do not concur in the further direction, nor in all that is said in the opinion.

¶2The opinion assumes that there is no defense to the petition, and the district court cannot upon a second hearing follow the opinion and at the same time enter a decree for the defendants, notwithstanding a perfect defense may have been pleaded and proved.

¶3I do not agree to the statement that mutual wills executed in conformity to a preceding oral contract constitute, with the contract, an integral part of one transaction, nor that the respective testators are powerless *606to revoke their wills. The wills may furnish written evidence to take the oral contract without the statute of frauds, and if either testator subsequently, in violation of his contract, revokes his will or devises to another the property described in the oral contract, the beneficiaries whose rights are last in point of time will hold the property as trustees for the benefit of the senior devisee.

¶4Furthermore, a decree of specific performance, within the limits of legal discretion, may be granted or withheld according to the circumstances of the case. In the case at bar neither will refers to any contract, nor can it be ascertained from an inspection of them that they were executed in conformity to an antecedent agreement. If evidence competent to establish that essential link in the plaintiffs title be not produced upon a trial, she should not prevail. If that evidence be produced, still there may be proof of such fraud, mistake, unfairness, hardship, rescission, or of changed conditions, as will justify a judgment for the defendants.

¶5For these reasons, I go no further than to say that the petition states facts sufficient to constitute a cause of action in the plaintiff’s favor, and the district court erred in sustaining the demurrer.

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