Board of Education v. Browning

ELDRIDGE, Judge,

dissenting:

The Court decides today that when the “aunt” of an equitably adopted child dies intestate, when the deceased had no “heirs” as defined by statute, and when the contest over the estate is between the equitably adopted child claiming through *296her parent and the State claiming by escheat, the State should prevail. Neither the cases nor reason support this result.

“Equitable adoption” is a principle of equity law. The doctrine is typically applied when a “parent” has entered an arrangement to adopt a child that is not carried out according to the statutory requirements but when both have acted as if there were a parent-child relationship. See McGarvey v. State, 311 Md. 233, 236-238, 533 A.2d 690, 691-692 (1987). As the majority points out, the doctrine is rooted in the notion that it would be “inequitable and unjust to allow the parent to escape the obligations of an adoptive parent by failing to comply with the agreement.” Consequently, for purposes of inheriting from the parent, courts will place the child “in the position he would have been in, had he been adopted.” McGarvey v. State, supra, 311 Md. at 238, 533 A.2d at 692; Besche v. Murphy, 190 Md. 539, 549-550, 59 A.2d 499, 505 (1947). Maryland recognizes the doctrine of equitable adoption. McGarvey v. State, supra, 311 Md. at 238, 533 A.2d at 692.

Although this Court has not defined the contours of the doctrine, some other jurisdictions have refused to allow the equitably adopted child to inherit through the equitably adopting parents in a contest between the equitably adopted child and a legal heir of the decedent. In re Estate of Olson, 244 Minn. 449, 70 N.W.2d 107 (1955); Menees v. Cowgill, 359 Mo. 697, 223 S.W.2d 412 (1949), cert. denied, 338 U.S. 949, 70 S.Ct. 488, 94 L.Ed. 585 (1950); Pouncy v. Garner, 626 S.W.2d 337 (Tex.Ct.App.1981).

In general, I agree that an equitably adopted child should not share in the intestate estate of a collateral “relative” at the expense of the legal heirs of that relative. The statutory laws of descent and distribution are a legislative attempt to divine how the decedent would have disposed of his or her property had there been a will. Barron v. Janney, 225 Md. 228, 234-235, 170 A.2d 176, 180 (1961). It is not unreasonable, absent a will, to speculate that a deceased would have preferred that his or her property devolve upon a legal heir rather than a person with whom the deceased had no adoption arrangement.

*297Not one case cited by the majority, however, involves a contest between the State and an equitably adopted child. The Court merely assumes that the same considerations which have defeated the claim of an equitably adopted child, in a contest with a legal heir, also apply in this case. This assumption, however, overlooks the State’s unfavorable position in the intestate succession scheme. Because “society prefers to keep ... property within the family as most broadly defined, or within the hands of those whom the deceased has designated,” escheat is disfavored and is enforced only as a last resort. United States v. 198.73 Acres of Land, More or Less, 800 F.2d 434, 435 (4th Cir.1986) (emphasis added). Since the law disfavors escheat, the equitably adopted child who has served as a dutiful family member should be entitled to the estate of her aunt. Furthermore, the factors that weighed against the equitably adopted child in a contest with an heir have no relevance here, for unlike those who would be entitled to take as heirs, the State has no “family” connection to the intestate decedent. It functions solely as a repository of last resort for the decedent’s estate should there be no family members.

In deciding that Paula Browning is not entitled to the estate of Eleanor Hamilton, her “aunt,” the majority relies on reasoning that is either inconsistent or circular. The majority asserts that “[although Paula correctly points out that es-cheats are not favored by law, ... Maryland law is crystal clear that if no legal heirs exist, the decedent’s property escheats to the local board of education” (citations omitted) (emphasis added). If, by “legal heirs,” the majority means the legal heirs as defined by statute, then the statement is inconsistent with the Court’s view that one who is equitably adopted, even though not included among the statutory heirs, is permitted to inherit from an intestate equitably adopting parent. If, on the other hand, the majority means, by using the term “legal heir,” simply a person who is entitled to inherit, then it has begged the question. The reason the parties are before this Court is for a determination of who is *298legally entitled to inherit. Equitable adoption is one of the reasons which entitles a person to inherit. The result is that the Court has decided today, based on the most intellectually unsatisfying “reasons,” to deprive Paula Browning of an inheritance.

The majority also ignores the fact that this is not simply a case where the relationship between Paula and Marian Hutchinson, the deceased’s sister, is based entirely upon equitable adoption. In this case, Hutchinson had married Paula’s biological father and, as a result, became her stepmother. According to Maryland Code (1991 RepLVol., 1993 Cum.Supp.), § 3-104(e) of the Estates and Trusts Article, based on this relationship, Paula would be a legal heir of Marian Hutchinson. To assume, in light of this, that the deceased, leaving no will, would have preferred her property to go to the State by escheat rather than to the legal heir of her sister compounds the inequity.

In effect, the Court has said today that when Eleanor Hamilton died intestate, she would have preferred to leave her estate to the government rather than to Paula Browning who, although never formally adopted, presumably because of oversight, was a member of the family for over seventy years. I do not believe that such a result would have been intended by the deceased.