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Spreckels v. Spreckels

Supreme Court of California
158 P. 537 (1916)


Anna Spreckels and Claus Spreckles were married from 1852 until the death of Claus in 1908. During their marriage, Anna and Claus had five children. After Anna's death in 1910, three of those children, Rudolph Spreckles, Claus A. Spreckles, together as executors of the wills of Anna and Claus, and individually with Emma Ferris (plaintiffs) filed suit against the other two children, John Spreckles and Adolph Spreckles (defendants). The suit alleged that Claus Spreckles had provided lifetime gifts to John and Adolph of community property valued in excess of $25,000,000.00, while the property remaining in the community at the time of Claus’s death was valued at less than $10,000,000.00. Anna Spreckles was aware of those gifts and was aware that the will of Claus, admitted to probate in 1909, expressly described the gifts Claus had made to John and Adolph and therefore did not include any testamentary disposition for their benefit. Several months later, Anna Spreckles executed a will that devised her entire estate to Rudolph, Claus A., and Emma. Anna's will expressly excluded any bequest to John and Adolph, stating as explanation that Claus had already advanced a large part of his estate to them. In bring suit, Rudolph, Claus A., and Emma alleged that, because Anna did not provide written consent to any of the gifts made by Claus during his lifetime, those gifts were void, and those gifts, or the value of the gifts, must be accounted for as part of the community estate. The trial court granted a demurrer filed by John and Adolph and dismissed the action. Rudolph, Claus A., and Emma appealed the trial court's decision.

Rule of Law


Holding and Reasoning (Shaw, J.)

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