Constitution Bank v. Olson

CIRILLO, Judge,

dissenting.

I respectfully dissent from the majority’s decision which, in my opinion, adheres far too rigidly to the elements of tenancy by the entireties without considering the inequitable results in this case. Equity requires us to consider not only the rights and interests of Robert and Elizabeth Olson, but the rights and interests of Constitution Bank as well.

Tenancy by the entireties is a “unique form of co-ownership grounded in the common law concept that husband and wife were but one legal entity.” Clingerman v. Sadowski, 513 Pa. 179, 519 A.2d 378 (1986). Essentially, a tenancy by the entireties is based on the uniqueness and unity of the marital relationship. Id. In this type of ownership, the husband and wife individually own the entire or whole property, and not one-half or a divisible portion. Id. Given such unity, neither *148spouse may deprive the other spouse of the use and/or enjoyment of the entireties property; and neither spouse may sever or encumber the property without the consent of the other spouse. Schweitzer v. Evans, 360 Pa. 552, 63 A.2d 39 (1949). Similarly, property that is conveyed to or titled as “husband and wife” is considered entireties property, and is not subject to attachment by one of the spouse’s creditors. Shapiro v. Shapiro, 424 Pa. 120, 224 A.2d 164 (1966); see also Patwardhan v. Brabant, 294 Pa.Super. 129, 439 A.2d 784 (1982).

However, the enactment of the Married Women’s Property Acts1 questioned the continued need for tenancy by the entireties. Wallaesa v. Wallaesa, 174 Pa.Super. 192, 100 A.2d 149 (1953). Pursuant to these Acts, women no longer require legal protection because they have achieved the same property rights as their husbands. Pennsylvania, however, chooses to retain the common law concept of tenancy by the entireties, which views a husband and wife as a single entity. DiFlorido v. DiFlorido, 459 Pa. 641, 331 A.2d 174 (1975); Madden v. Gosztonyi, 331 Pa. 476, 200 A. 624 (1938). Therefore, in determining whether a tenancy by the entireties has been created, the intention of the husband and wife is controlling and will be given effect. Brown v. Brown, 330 Pa.Super. 324, 479 A.2d 573 (1984).

In the instant case, I find the majority’s strict adherence to the traditional attributes of tenancy by the entireties unwarranted. The finding of a tenancy by the entireties, under these circumstances, only serves to enable a party to avoid payment of a debt.

Moreover, the intent of the Olsons to not hold the accounts as entireties property is clear from the language on the accounts naming “Robert P. Olson and Elizabeth Q. Olson *149JTWROS.” In addition, the record indicates that Robert Olson had a thorough understanding of the effects of titling property as husband and wife. The fact that during his twenty years of marriage he has always knowingly held property jointly with his wife as tenants by the entireties, is indication that that Robert Olson understood the distinction between the various tenancies available to property owners.

The application of tenancy by the entireties to these accounts allows one spouse, or both spouses, individually, to protect their jointly held property. Such an outcome prevents the bank from collecting on a debt to which it is legally entitled. Tenancy by the entireties was never intended to work such an inequity. I, therefore, dissent from the majority’s analysis and result.

. Act of May 23, 1887, P.L. 170, and Act of June 8, 1893, P.L. 344 Sec. 1 (48 P.S. § 31). The Act of 1893 permitted married women to lease, sell, and own real estate, but required the consent and participation of their husbands in such transactions. The Act of 1957, however, equalized a married woman’s rights with the rights of a married man. A woman’s property rights were further enhanced in 1971 with the Equal Rights Amendment to the Pennsylvania Constitution. See Pa. Const., art. I, § 28.