Watson v. Santalucia
West Virginia Supreme Court of Appeals
427 S.E.2d 466 (1993)

- Written by Sean Carroll, JD
Facts
Frank Cirigliano owned 2,000 shares of Citizens Bancshares, Inc. (Citizens). Cirigliano’s will devised 100 shares each to John Law, Marino Paletti, and Teresa Calabrese (defendants). The will left the residue of Cirigliano’s estate to Geraldine Watson and Virginia Paletti (plaintiffs). On April 21, 1990, Citizens executed a four-for-one stock split, increasing the number of shares of the company by four times, while decreasing by one-fourth the par value of each share in existence prior to the split. Due to the split, Cirigliano’s number of shares increased from 2,000 to 8,000, but his proportionate interest in the company remained the same. On May 15, 1990, Cirigliano died. The circuit court ruled that John Law, Marino Paletti, and Teresa Calabrese were entitled to only their 100 shares of stock, regardless of the decrease in value the stock split caused. John Law, Marino Paletti, and Teresa Calabrese appealed.
Rule of Law
Issue
Holding and Reasoning (Neely, J.)
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