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Home / CalHiSports Insights / Max Nyrop: Nothing But Zeroes
Max Nyrop: Nothing But Zeroes
By Mark Tennis
Alameda Senior Max Nyrop Finishes Just Two Innings Shy Of State Record For Consecutive Scoreless Innings Pitched •
Nyrop at Alameda's Lincoln Park on Feb. 18. (Berry Evans III photos)
When a pitcher in baseball doesn't give up a run and posts a shutout, the manager or coach is never questioned about poor sportsmanship. A run is a run and any batter can run into a fastball at any time and launch one over the fence for a round-tripper. Max Nyrop tested that theory a lot in 2018.
During the California high school season in 2018, the longtime state record of not allowing a run for consecutive innings by a pitcher came under assault. At first by two players, and then a third. The crux of this story is that the third player, Alameda High's Nyrop, was only a junior. He took an active streak into the 2019 season.
According to the Cal-Hi Sports State Record Book & Almanac, the state record until last season for most consecutive scoreless innings was set at 59 in 1970 by small school pitcher Jerry Jordan of Avenal (CIF Central Section).
In the CIF San Diego Section, Jordan's record first came into focus last May when pitcher Joe Magrisi from Torrey Pines-San Diego surpassed that section's record of 42 set in 1982 by future major leaguer David Wells of Point Loma-San Diego. Magrisi, who later would be named Mr. Baseball State Player of the Year, extended his record into the postseason. It was halted at 54.2 innings in the first round of the section playoffs.
One week later, it was reported in Pasadena and San Gabriel Valley newspapers that Maranatha-Sierra Madre junior Dawson Netz was piling up the shutouts. Although his team won a Southern Section Division III title, Netz's streak was snapped in a playoff game against Palos Verdes-Palos Verdes Estates. The reported total of 59.1 innings was above Jerry Jordan's state record, but more info was needed. That's because in many record books, one-third or two-thirds of an inning isn't counted. It reverts to the total from the previous inning.
In the case of Jerry Jordan, due to the information stored by Central Section historian Bob Barnett, it was determined his scoreless streak did indeed end squarely at 59 innings. And thus, Netz was given credit for a new state record at 59.1 innings.
This is where Max Nyrop comes in. According to Alameda statistician Jim Quilici, Nyrop had only zeroes over his final 41 innings of the regular season. Max then pitched consecutive shutouts for the Hornets in the North Coast Section Division II playoffs. He tossed a four-hitter in a 7-0 win over Newark Memorial and a three-hitter in a 1-0 victory against Drake-San Anselmo. He didn't pitch in the NCS title game, so his consecutive innings streak didn't end at 55 and was set to start up again this season.
Nyrop needed just 4.2 scoreless innings to start this spring to break Netz's record. He only got half of that. Nyrop surrendered his first run of 2019 after just 2.1 innings of work in a 7-5 win against Tokay-Lodi on Feb. 23. His streak ended at 57.1 innings, good enough for the state's third-best all time.
It was a unique way to start a season, but Nyrop had a mature way of looking at it.
"Of course, there's some added pressure. But I just got to get out on the bump and approach it the same way as before," Nyrop said during a phone interview on Presidents Day weekend. He had just returned from a trip to Minnesota to visit colleges. "It's got to be pitch by pitch, stop by stop, and get outs. If (the record) comes, it comes. I'm not going to worry about it too much."
Both Nyrop and Alameda coach Ken Arnerich love the fact that a record like consecutive scoreless innings is a clear reflection of the team. In addition to one swing of the bat creating a run to score, so can a hard-hit grounder that isn't fielded cleanly, allowing a run to score on an error. Such a streak requires almost perfect defense.
"First, the defense we had last season was the best I've ever had," Arnerich said. The coach is beginning his 17th season with the Hornets. "It takes defense like that to do something like that. Second, as a pitcher, Max just paints the zone. In five or six of his games last season, he won on 65 pitches or less. He doesn't walk anyone and pitches to contact."
Nyrop plays first base during the 2018 North Coast Section Div. II Championship. (Dennis Lee photo)
For the season, in earning all-state underclass honors, Nyrop had a 9-0 record on the mound with a 0.85 ERA. He doesn't throw with the velocity that generates Division I college offers or MLB Draft talk. Both the pitcher and coach are working on that.
"I would like to play (in college) as long as I can," Nyrop said. "I'm definitely working on that velo plus change-up. Deception is my major tool. I do all I can to keep batters off balance."
"We went through all of his games on tape and no one really barreled him up on any swing all season," Arnerich said. "I think we will be able to get him up to 85 or 86 (mph). That's perfect for high school and I think he'll start to get Div. II looks."
The improvement since last season may also come for Nyrop with bat in hand. He was one of the team leaders as a junior with a .341 batting average with 18 RBI. While he didn't pitch in that NCS final, Max played first base and came up in a tie game with Maria Carrillo-Santa Rosa in the bottom of the seventh inning. He promptly rapped out a base hit. Not known for his speed, he made it to third base on a throwing error. Then he watched as a pinch runner scored on a game-winning single by KW Quilici.
The 4-3 win capped a 27-2-1 season; the Hornets were later named the Cal-Hi Sports Division II State Team of the Year. With Nyrop and senior teammate Bryan Woo (as much of a pitching ace as Nyrop), they helped Alameda post 15 shutouts as a team on the season. That isn't a state record, but is on the all-time state list.
Nyrop stands at first base following a seventh-inning single during the NCS Championship. (Dennis Lee photo)
Besides Woo, five other starting players have graduated, so it may be difficult for similar success. Regardless, Nyrop thinks there will be no limitations.
"It's going to be hard to fill their shoes," Nyrop said. "But I have full confidence the younger players are going to step up. We may not have the initial talent when you first look at us, but I think we can do some damage."
Nyrop has the full confidence in Arnerich to get the team ready to defend its title in May.
"It's great to play in a place like Alameda," Nyrop said. "Baseball is so important and the Arnerich family is known by everyone. Our coach is a legend and just to be coached by him is such an honor."
Many of Nyrop's teammates from this year and last year have played together since they were 5 or 6 years old in the Alameda Little League. Some of them also were on a World Little League team that played in Japan when Max was 13.
The city of Alameda's high school history is more famous at rival Encinal. That's where MLB Hall of Fame slugger Willie Stargell attended. It's also where recently retired Encinal coach Jim Saunders had some great teams led by players such as Jimmy Rollins, Dontrelle Willis and Osiris Johnson, the 53rd pick in last year's MLB Draft by the Miami Marlins.
Nyrop's streak was just a little bit more history to the baseball fabric of Alameda. What could be next?
High School BaseballMPTicker
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About Mark Tennis
Mark Tennis is the co-founder and editor for Cal-Hi Sports. His work appears special to SportStars.


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Great looking sample of Ostrich Jon. Smooth straight (not twisted) flues, beautiful even fibers. Super...and I'll bet that feather came from our mutual friend John McLain at FeathersMc. Always top notch materials and his mini ostrich is the best!!!
Good herl is hard to find. Are the two photos the same feather?
(03-19-2018, 09:38 PM)Ronn Lucas Sr. Wrote: Good herl is hard to find. Are the two photos the same feather?
This is one that I got from Jim Haswell years ago and as you can see I do use it. The size and density of the barbs is the best I've come across so I use this one sparingly. The only challenge I face with it, as I understand it came from and antique hat, is that it tends to be fragile and I've broken a few of them while wrapping them.
You might want to look for more in different sizes (barbule size) so you can use herl proportional to the size fly. I have about 12 or so and a few dyed too. Great herl is not common. Dense barbules are the most desired.
Its short flued and very dense barbary ostrich I think?
Its the best herl I have ever used but does tend to be fragile!!


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(Slightly Old News) Mickey Mouse movie?
Thread starter Smashgoom202
Smashgoom202
Dry Bowser
So, I was looking down the Wikipedia page for the Animated Disney Canon. Next year's entry into the series is "Wreck-It Ralph", which actually sounds pretty interesting, being about video games and all. Something else caught my eye, though. After Wreck-It Ralph, two more movies are apparently in the works: an adaption of The King of the Elves (a sci-fi short story written by Philip K. Dick in 1953) and...
A feature film starring Mickey Mouse?
http://www.bleedingcool.com/2011/03/24/scoop-mickey-mouses-first-feature-length-film-being-developed-at-disney/
By the time this was announced, it has yet to be greenlit, so I don't know if there are anymore details about it...
For those of you unaware, as far as the Animated Disney Canon goes, Mickey has only been featured in about 3 of them, namely Fantasia, Fun & Fancy Free, and Fantasia 2000. Any and all other movies, namely the direct-to-DVD brand of movies, don't count. And even then, Mickey wasn't the main focus. So to have the Walt Disney Animation Studios, the studio responsible for Snow White and the Seven Dwarfs, Fantasia, Bambi, and all your other favorite Disney movies both new and old, make a movie with Mickey Mouse star in his own feature-length movie (alongside Donald Duck and Goofy)...
Well, I'd say it's about time.
I know it's really too early to speculate, but since this IS Disneycember (see ThatGuyWithTheGlasses.com to see what I'm talking about), I figured it was worth mentioning.
The guy who brought up this idea was one Burny Mattinson, a veteran Disney animated from the 60's who also worked on the recent Winnie the Pooh movie, who basically said he had an idea to feature Mickey, Donald, and Goofy in their own movie, which sounds really vague... I wonder what exactly he had in mind. Personally, I hope he uses a lot of classic Disney characters. Not just mainstays like Minnie Mouse, Daisy Duck, Pluto, and Pete, but also Clarabelle Cow, Horace Horsecollar, Hell, why not throw in Oswald the Lucky Rabbit as well, since Epic Mickey finally had them reunite.
There's just so much potential in this, and given that this is Disney's mascot we're talking about, Disney's DEFINITELY going to have to give this idea some care and attention... if they let it pass, that is.
MarioKartRPG
"About time" is a severe understatement.
They should have done this in the fifties.
I think by the 50's, Mickey was beginning to lose his momentum and character, and wasn't as popular as he used to be... But you ARE right.
UltraMario
Well, I kinda already made a Mickey thread here for all your favorite Mickey cartoons, but that's not really relevant whatsoever. :P. http://www.marioboards.com/index.php?topic=14852.0
Pinkie Pie said:
Well, THIS topic is about the movie, while yours is about Mickey cartoons. So it's different! :P
Not sure if this is technically related or not, but Mickey Mouse and Roger Rabbit are going to star in an animated remake of "The Stooge":
http://www.ign.com/articles/2013/03/13/mickey-mouseroger-rabbit-movie-picks-up-steam
...Well... That's something.

redpajama_set_name: RedPajamaCommonCrawl


text:
Q: Concatenation not working inside of function in SQL Server I am converting minutes to days and hours. When I am using following code, it works fine
declare @theMinutes int
Set @theMinutes = 1449

select cast(@theMinutes / 1440  as varchar)
        + ' Day(s) '+ cast((@theMinutes % 1440 / 60) as varchar)
        + ' Hour(s) '+ cast(@theMinutes % 60    as varchar)
        + ' Minute(s)' AS COLUMN_A

and displays result
1 Day(s) 0 Hour(s) 9 Minute(s)

But when I use this to write a function, then it is only returning 1, the rest things are not getting concatenated
Create function [dbo].[ConvertMinToDays]
(
    @theMinutes int
)
RETURNS varchar
AS
BEGIN
    Declare @convertedStr varchar(200)

    SET @convertedStr =  cast(@theMinutes / 1440  as varchar(10)) + ' Day(s) '
    + cast((@theMinutes % 1440 / 60) as varchar(10))+ ' Hour(s) '
    + cast(@theMinutes % 60 as varchar(10)) + ' Minute(s)';

    return  @convertedStr;

END

GO

SELECT dbo.ConvertMinToDays(1449) as COLUMN_A

Can Anybody help me , where i am going wrong ??

A: Change
RETURNS varchar

to
RETURNS varchar(200)

I'm assuming its only going to return one character otherwise

A: You are returning a varchar
Change it to
RETURNS varchar(200)

redpajama_set_name: RedPajamaStackExchange


Too committed to the starry-eyed Piscean ideals of love and desire and wanting to have things be the way they ought to be because it is the right way.
Your upper lip inching past the edge of the rim of the cup to taste what I have crafted just for you.
I can clearly remember the hiss and scream of the espresso machine in the background, Miles Davis playing in the cafe, the cigarette in my left hand, and the pen in my right hand- rushing hurriedly across the page, trying so hard to keep up with my mind.


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Brexit – Theresa May's speech on Our Future Partnership
carolineheath 2 March 2018 No comments
In a speech today at Mansion House, the Prime Minister set out the Government's vision for the future partnership the UK is seeking with the EU following Brexit.
The five tests
First, the Prime Minister set out her five tests for the agreement on the future partnership with the EU, which were that it should:
Respect the result of the referendum;
Be an enduring agreement;
Protect people's jobs and security;
Deliver an outcome consistent with the kind of country we want to be;
Strengthen our Union of nations and bring our country back together.
Why existing trading models are not an option
She acknowledged that existing models for co-operation between the EU and a third country would not pass these tests, and therefore would not work for the UK or the EU.
For example, under the Norway model, the UK would stay in the single market, but would have to implement new EU legislation automatically and in its entirety – and it would also mean continued free movement.
Other possibilities include negotiating a free trade agreement similar to the one Canada has recently negotiated with the EU, or trading on World Trade Organisation terms.
But these options would mean a significant reduction in access to each other's markets compared to what is currently enjoyed.
Instead the UK is looking to agree the broadest and deepest possible agreement – covering more sectors and co-operating more fully than any FTA anywhere in the world today.
"We need to strike a new balance. But we will not accept the rights of Canada and the obligations of Norway," she said.
Five foundations for the future trading relationship
To realise this ambition she called for five foundations that must underpin the trading relationship:
Reciprocal binding commitments to ensure fair and open competition;
A completely independent arbitration mechanism;
Ongoing dialogue with the EU, in particular between our regulators;
An arrangement for data protection that goes beyond an adequacy agreement;
Maintaining the links between our people.
On goods, a fundamental principle is that the UK-EU border should be as frictionless as possible, without any tariffs or quotas. With this in mind the UK is seeking a comprehensive system of mutual recognition to ensure that, as is the current situation, products only need to undergo one series of approvals in one country.
The Prime Minister also set out two potential options for the future customs relationship with the EU: a customs partnership and a highly streamlined customs arrangement, as well as some specific provisions for the unique situation in Northern Ireland.
Customs partnership
Under this proposal, at the border the UK would mirror the EU's requirements for imports from the rest of the world, applying the same tariffs and the same rules of origin as the EU for those goods arriving in the UK and intended for the EU. By following this approach, all goods entering the EU via the UK pay the right EU duties, removing the need for customs processes at the UK-EU border.
But, importantly, a mechanism could be put in place so that the UK would also be able to apply its own tariffs and trade policy for goods intended for the UK market. This approach would require the means to ensure that both sides can trust the system and a robust enforcement mechanism.
Streamlined customs arrangements
Option two would be a highly streamlined customs arrangement, where the UK and EU would jointly agree to implement a range of measures to minimise frictions to trade, together with specific provisions for Northern Ireland.
Firstly, measures to ensure the requirements for moving goods across borders are as simple as possible.
This would involve continuing to waive the requirement for entry and exit declarations for goods moving between the UK and the EU.
In addition, goods moving between the UK and the rest of the world should be allowed to travel through the EU without paying EU duties and vice versa.
Second, measures to reduce the risk of delays at ports and airports. For example, recognising each other's "trusted traders" schemes and drawing on the most advanced IT solutions so that vehicles do not need to stop at the border.
Third, both side should continue their cooperation to mitigate customs duty and security risks.
And fourth, measures to reduce the cost and burden of complying with customs administrative requirements, including by maximising the use of automation.
Further specific measures were proposed to recognise the unique circumstances in Northern Ireland, and the shared commitments to avoiding a hard border.
On services, the UK is seeking to establish a broader agreement than ever before. Whilst recognising that certain aspects of trade in services are intrinsically linked to the single market, and therefore future market access in these areas would need to be different, Theresa May said that new barriers should only be introduced where absolutely necessary.
The UK wants to limit the number of barriers that could prevent UK firms from setting up in the EU and vice versa. It wants to agree an appropriate labour mobility framework that enables UK businesses and self-employed professionals to travel to the EU to provide services to clients in person and that allows UK businesses to provide services to the EU over the phone or the internet. The same arrangements would apply for EU firms providing services to the UK.
Two areas that have never been covered in free trade agreements in any meaningful way before are financial services and broadcasting. Theresa May recognised that the UK cannot have the rights of membership of the single market, such as 'passporting' in financial services and 'country of origin' in broadcasting. But emphasised that future arrangements should not be bound by existing precedent.
The Chancellor will be setting out next week how financial services can be part of a deep and comprehensive partnership with the EU.
The negotiations
The Prime Minister acknowledged that there would be ups and downs in the months of negotiations ahead, "As in any negotiation, no-one will get everything they want."
The PM concluded by saying: 'My message to our friends in Europe is clear. We know what we want. We understand your principles. We have a shared interest in getting this right. Let's get on with it.'
Reaction from the EU
The EU's chief Brexit negotiator Michel Barnier welcomed the speech, saying it provided "clarity" about the UK leaving the single market and customs union and a "recognition" that trade-offs will inform future talks on a deal.
But the European Parliament's Brexit co-ordinator Guy Verhofstadt was less impressed.
He said: "Theresa May needed to move beyond vague aspirations, we can only hope that serious proposals have been put in the post.


text:
There was once a fine gentleman, the whole of whose equipment existed of a boot-jack and a comb, but he had the finest shirt Collar in the world, and it is about this Collar that we are to hear the story. He was now of an age to think of marrying, and it so happened that at the wash gate he met with a garter.
"Dear me," said the Collar; "never have I seen any one so slender, so refined, so soft or so charming. Might I ask your name?"
"That I shall not tell you," said the Garter.
"Where do you reside?" asked the Collar.
But the Garter was very shy, and thought the question an awkward one to answer.
"You must be a girdle," said the Collar; "a sort of inner girdle! I see, I see; you serve both for use and ornament, little lady."
"You must not address me," said the Garter. "I do not think I have given you any encouragement to do so."
"Oh, if anyone is as beautiful as you are," said the Collar, "that is encouragement enough."
"Do not come too near me," said the Garter; "you look so much like a man."
"Well, yes, I am a fine gentleman," said the Collar. "I own a boot-jack and a comb." Now this was really not the truth; it was his master who owned them, but he was boasting.
"Don't come near me!" said the Garter. "I'm not accustomed to it."
"Miss Prim!" said the Collar. They were then taken out of the tub, starched, and hung on a chair in the sun, and afterwards laid on the ironing board. Then came the hot iron.
"Lady!" said the Collar. "Little widow lady, I'm getting quite hot, a change is coming over me! All my folds are being flattened out. You'll burn a hole in me. Will you be mine?" "Rag!" said the iron, passing proudly over the collar; she fancied herself a steam engine travelling along the rails and dragging a train. "Rag!" said she. The Collar had become ravelled at the corners, so now came the paper-scissors, to cut the ravelling off.
"Oh!" said the Collar. "You are, of course, the Première Danseuse. How you do stretch your legs; the most charming thing I ever saw. No human being can do the like."
"I know that," said the Scissors.
"You deserve to be a countess," said the Collar. "My whole property consists of a fine gentleman, a boot-jack and a comb. Oh, were I but a count!"
"Are you proposing to me?" said the Scissors, much annoyed, and gave him a smart cut; so he was dismissed from service.
"I suppose I must try the comb," said the Collar. "It's very remarkable how you keep all your teeth little lady! Have you never thought of becoming engaged?"
"Yes, to be sure I have," said the comb. "I'm engaged to the boot-jack."
"Engaged?" said the Collar? There was nobody left to propose to, so he took to despising the whole business.
A long time passed by, and the Collar found himself in a box, at the paper mill, with a vast collection of rags, the fine ones by themselves and the coarse by themselves, as is right and proper. All of them had a great deal to tell, but the Collar most of all, for he was a regular prating Jack.
"I've had a terrible lot of sweethearts," he said; "I hadn't a moment's peace. In my time I was a fine gentleman – starched, too. I had a boot-jack and a comb, which I never used. You ought to have seen me then; seen me when I was laid aside. I shall never forget my first love! A girdle she was, most delicate and soft and charming. She threw herself into a washing-tub for love of me. Yes, and there was a widow, who was burning hot, but I let her alone and she turned black. And there was a première danseuse; she gave me the scar I carry now – she was so jealous. My own comb, too, fell in love with me, and lost all her teeth from unrequited affection. Yes, I've had many such experiences; but what caused me most pain is the Garter – I should say the girdle – who went into the washing-tub. I've a great deal on my conscience, and I'm really desirous of being made into white paper."
And so they were; all the rags were made into white paper, but the Collar was made into precisely this bit of white paper you see here, on which this story is printed; and that's because he boasted so fearfully in his later days of what never happened. And we must take care not to behave like that, for we really can never be sure that we shan't get into the rag box, one of these days, and be turned into white paper and the whole of our story printed on us, even the most private bits, and be obliged to run about telling it, like the Collar.
Images © Nicola Naismith Ring 2003
The Shirt Collar was written by Hans Christian Andersen (1805-1875), and was translated from Danish by M.R. James (1862-1936) as part of Hans Andersen Forty-Two Stories (1930).


text:
Q: Is there any problem with popen stream to be closed after fdopen I'm seeing a strange issue. Sample code is included below
When this code is run with valgrind, it complains that the memory allocated with popen is still reachable. Should i worry about this warning? If yes, what is a possible solution?
       Func1()
            FILE *fp = NULL;
            int fd = 0;
            fp = popen(g_cmd, "r");
            fd = fileno(fp); // store fd for later processing.
            ...

       Func2(fd)
            FILE *popen_fp = NULL;
            popen_fp  = fdopen(fd, "r");  // Convert fd to File pointer.
            if (popen_fp) pclose(popen_fp);

==11748== 256 bytes in 1 blocks are still reachable in loss record 1 of 1
==11748==    at 0x4C29F73: malloc
==11748==    by 0x5542627: popen@@GLIBC_2.2.5
LEAK SUMMARY:
==11748==    definitely lost: 0 bytes in 0 blocks
==11748==    indirectly lost: 0 bytes in 0 blocks
==11748==      possibly lost: 0 bytes in 0 blocks
==11748==    still reachable: 256 bytes in 1 blocks


Pão de Canela – Shall we brunch?
I first discovered Pão de Canela when trying to come up with a place to have an affordable brunch with friends – I was enchanted by the location as well as the food, and ended up having a fabulous time. You, as I did, may think that when we're with friends, sometimes it seems no matter where we are, we always end up having fun; but I've been coming back to Pão de Canela, and no matter who I am with, I always ended up having an amazing experience and a stomach full of yummy food… so I'm starting to think that this "secret-in-plain-sight" in Lisbon should be shared with everyone!


text:
New international report reveals Qatar ties with terrorism still deep
According to the findings, there is still progress to be made in terms of cracking down on terror finance from Qatar (AFP)
Al Arabiya English, London Thursday, 30 November 2017
Qatar's ties with terrorism are continuing, according to a report by the British think tank the Henry Jackson Society.
The group suggests a four-point plan of action to the British government in order to push to Qatar to change its behavior.
The new report examines the charges made against the Qatari government by other Gulf states and questions whether Doha is engaged in power politics and bolstering groups and individuals, many of whom are dangerous radicals, that undermine its neighbors and regional stability.
WATCH: Qatar played 'dirty game' by supporting terrorists
The think tank said that the report makes the following findings:
- Up to $200 million has been paid to jihadist militant groups Al-Nusra and Hay'at Tahrir al-Sham in the form of ransom payments, either facilitated or made directly by the Qatari government, giving credence to the accusation that the country funds terror by stealth.
- Though Qatar has for some time positioned itself as a mediator and safe-haven for dissidents, it also host of terrorist organizations.
- While Britain should avoid publicly taking sides in the broader dispute between the Gulf States, the Government should use its influence in the region to press for changes in Qatar's ransom payments policy, the appearance of extremists on state-run media and make major improvements in human rights.
Commenting on the report, Kyle Orton, author and research fellow at the Henry Jackson Society, summarized:
"The report raises some troubling questions about Qatar's regional policies. Despite finding that in a number of areas Qatar has made significant improvements over time, it shows that the effects of prior policies—notably in Syria and Libya—will be lasting and deleterious. There is still progress to be made in terms of cracking down on terror finance from Qatar and the use of its state-run media as a platform for incitement and the dissemination of extremism."
Last Update: Thursday, 30 November 2017 KSA 11:05 - GMT 08:05
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Bloomberg's white house correspondent Jennifer Jacobs tweeted on Wednesday that "after Trump praised the ...


text:
Saturday 16 January 2021, 02:09 AM
Bharat Defence Kavach
India Defence
Defence Affairs
Aero/Space
Defence Tenders
IS THERE A CHALLENGE FROM THE PLAAF?
By Air Marshal Dhiraj Kukreja (Retd.) | Bharat Defence Kavach | Publish Date: 7/24/2020 12:20:47 PM
Indian Air Force Pilots
Recent events of the last few months, on the border with China, both in the Eastern and Western sectors, have seen China's People's Liberation Army (PLA) deploy troops in border positions near Galwan and Pangong Tso in the Western Sector in Ladakh, and in the Naku La area of Sikkim in the East, representing a significant escalation in the ongoing regional competition between the two Asian powers. One admits, standoffs and limited clashes in disputed territory are not unprecedented, but these are different. These are the first major PLA incursions into territory that both sides' maps recognise as being on the Indian side of the Line of Actual Control (LAC) – the de facto border between the two countries. It is too premature to infer precisely what caused this latest escalation, and considering the massive concentration of troops and hardware of both armies in Ladakh, even as this piece is being written, whether the talks to de-escalate would be successful; nevertheless, one can possibly make an attempt to identify the various geostrategic factors which may have contributed to China's decision to mount this incursion.
Chinese Airforce pilots.
The decision to escalate tensions on the Indian border by China, even as it adopts a more conciliatory stance with some of its other neighbours, fits with what some scholars view as China's approach to counter-containment – the strategy of selectively and sequentially targeting individual members, of what it views as a nascent encircling alliance, in order to prevent such a tie-up. The incursions could also represent a form of coercive issue linkage, whereby it applies pressure on disputed territories to secure concessions with regards to another contentious issue. In the current case, China could be holding out an offer to withdraw from encroached Indian territory, as well as minimise the threat of further escalations, as a lever with which to shape Indian policies, which it considers as inimical to its interests.
It may interest the readers to learn that the entire border/LAC with India is under the jurisdiction of China's Western Theatre Command (WTC), which includes the erstwhile Tibet and Xinjiang military districts. On paper, PLA forces in the WTC operate at a significant advantage to their Indian counterparts; PLA fields 230,000 troops compared to the 225,000 troops which can be mobilised from India's Northern, Central and Eastern commands. However, the ground infrastructure with road and rail links on the Chinese side of the border, vastly outstrips Indian efforts, which translates in to a easy and rapid transfer forces to the region. In contrast, many of the roads on which the Indian Army relies upon, terminate some distance from the front lines of a likely conflict area; railheads are negligible! While India has made significant progress in developing its border area infrastructure, most of it is in the Eastern sector; that India has a lot of catching up to do, is undisputed.
China continues to invest heavily in logistics and infrastructure development in Tibet to facilitate rapid deployment in Tibet. As per one estimate, there are 14 major airbases and 20 small airstrips (cannot really support fighter operations) in Tibet from which PLA Air Force (PLAAF) can conduct its operations against India; the concentration of these airfields, however, is in the East, opposite Arunachal Pradesh and Sikkim, a few in the central Tibet region, while only three can be used against the IAF in Ladakh.
Ngari Gunsa, a new civil/military airfield in Lhasa, in SW Tibet, is at about 50 kms from the Uttarakhand border, but more than 200 kms from Leh; Khasgar and Hotan are in the Xinjiang region of the WTC, but at a distance of 570 kms and 330 kms, respectively, from Leh, although closer to the current area of dispute. A disadvantageous characteristic of operating from these airbases is their high elevation; almost all are at 4000m amsl, necessitating long runway lengths for takeoff and imposing severe limitations in the carriage of fuel and payload; aerial refuelling, hence, would become a critical essential to carry a reasonable payload against targets in Ladakh. Another unfavourable feature of operating from these airbases is the unpredictable weather due to the mountainous region, thus once again, imposing restrictions on operations. Nonetheless, these airbases can be utilised to launch operations against India, provided PLAAF uses the requisite aircraft!
These disadvantages are not so applicable for the IAF, which, apart from Leh, has all its launch-pads at a comfortable altitude, thus permitting full payload and fuel. As many as 31 Indian airfields, nine in the Western and 22 in the Eastern sector – are located close to the LAC. In addition, India has multiple advance landing grounds (ALG) in both sectors of which Daulat Beg Oldi (DBO), Fukche, and Nyoma, are in Ladakh, the area of current concern. IAF heavy-lift aircraft have landed on all three ALGs, thus facilitating quick response for the airlift of troops and other armament.
The number of aircraft that the PLAAF can field in the Tibet region, towards Aksai Chin, is another point for capability assessment. Recent movement of aircraft and assessments made there indicate an availability of about 150-200 aircraft of various types. Reportedly, variants of J-7, J-10, Su-27 and J-11 fighter aircraft are likely to be used against India in the current scenario; of these, fighters with a superior performance (Su-27, J-10/11) can be expected to be effective from the high-elevation airfields mentioned above, while operations with the J-7 would be severely constrained.
J-20, Chinese Fighter
The IAF can muster an equivalent or maybe, even a larger number of aircraft for use in Eastern Ladakh area; the number that can be deployed all along the LAC is very large, but it includes the Eastern and Central parts of the country too. Of course, the PLAAF can bring in more aircraft from other theatre commands for an India-contingency, but lack of proper basing facilities and the operational situation existing in the other regions would limit this number. One needs to remember, that while China is harassing India in Ladakh, it is itself vulnerable opposite Taiwan, in the East China Sea and the South China Sea, all fronts of its own making! This places the IAF at an advantage as against the numerical strength available to the PLAAF in the Ladakh area.
Even qualitatively, the PLAAF is at a disadvantage with respect to the IAF. Most of the PLAAF's existing fleet, made up primarily of J-10s, J-11s, SU-27 and SU-30, is not as capable as the IAF's Su-30 MKIs, Mirage-2000s and MiG-29UPGs, despite contrary claims by Chinese strategists and media mouthpieces. An aircraft that the IAF would do well to watch out for is the J-20, the latest, most modern and advanced aircraft in the PLAAF inventory. The J-20 entered service sometime in 2017; while its participation in exercises in the Tibet region of the WTC generated much hype in the Indian media, it has mainly been deployed opposite Taiwan in the Eastern Theatre Command (ETC), for obvious reasons. The PLAAF claims it to be a game-changer, but it may not be as much as a "Powerful Dragon" as claimed, since reportedly it has some serious limitations; the aircraft does not have as low a radar signature as claimed, especially in the side and rear aspects; originally designed to use Chinese turbofan engines, which have not been made available, the causes for which are not found in the open domain, the PLAAF is forced to use other Chinese/Russian engines that significantly compromise its stealth profile and manoeuvrability. In the long term, what should be of deeper concern to the IAF is the PLAAF demands for a long-range strategic bomber with a range of over 8000 kms, without refuelling, and a payload of over 10 tonnes; this, along with the latest variant of the H-6 bomber, the H-6K, that can carry six cruise missiles, which have a range of around 1,500 km, can blunt IAF's capability to launch its air power.
Sukhoi 30 Indian Fighter
The social media and the TV channels are abuzz with the news that some PLAAF fighter aircraft had been deployed in Skardu, in Pakistan Occupied Kashmir (POK); fact checks are to the contrary. Reports have indicated the presence of an IL-78, air-to-air refuelling aircraft, some time ago; the news could have been a part of psy-ops by China, although the possibility does exist. PLAAF and the Pakistan Air Force (PAF) have been carrying out joint exercises in the POK and Pakistan, the last being conducted in 2019. The axis may not be a threat at present, but requires close and constant monitoring.
This is just a broad comparison of numbers and types of fighter aircraft and may not make for a realistic assessment. IAF has a definite edge in the availability of helicopters, especially after the induction of the Apache gunship, and Chinook heavy-lift helicopter. Drones, air defence have not been included in this assessment; hence, a more detailed analysis needs to be done, which the author is quite certain that it would already have been completed in the required offices dealing with national security. Suffice it to say that the IAF is almost at par, if not holding an advantage against the PLAAF in the current area of concern. In so far as the entire WTC is concerned, the PLAAF, which always had a numerical advantage over the IAF, has, in the recent past, begun to edge past qualitatively too. The PLAAF threat is present, and considering the lethargy of the policy makers towards enhancing the IAF combat strength, one can only hope for the best in the unlikely event of an all-out war on two fronts.
Air Marshal Dhiraj Kukreja (Retd.)
India border with China,India-China border,Naku La,India China disputed territory,India China standoff
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Tag: Testamentary capacity
Testamentary Capacity: Knowledge and Approval
One of the components of testamentary capacity and a valid will is that the testator must have knowledge and approval of the contents of the will before it is signed.
In his book Capacity and Undue Influence (Toronto: Carswell, 2014), John E.S. Poyser discusses the distinction at page 235:
Lord Justice Moore-Bick went on to comment on the distinction between testamentary capacity, on the one hand, and knowledge and approval on the other, giving an elegant formulation to distinguish between them (emphasis added):
The use of the expression "knowledge and approval" is liable to give the impression that the court is concerned with whether at the time he executed the will the testator must be able to reconsider all the dispositions he has made. That would require testamentary capacity, but that is not what is meant by the convenient expression "knowledge and approval". Modern authorities recognise that a clear distinction is to be drawn between testamentary capacity and knowledge and approval. As the judge observed in this case
….testamentary capacity includes the ability to make choices, whereas knowledge and approval requires no more than the ability to understand and approve the choices that have already been made.
Paraphrasing a different comment elsewhere in the reasons for decision, the twin requirements of knowledge and approval in testamentary capacity ensure that the will is the product of the conscious intention of a sound mind. Knowledge and approval is the "conscious intention" in that formula.
Russell v Fraser (1980) 118 DLR (3d) 733 BCCA
"In my view it is clear from decisions of high authority that where the propounder of the will is shown to have participated in the drawing and preparation of the will and to take a benefit under the will, he must satisfy the conscience of the court that the part of the will under which he benefits had the full knowledge and approval of the testatrix. I refer to Fulton v. Andrews (1875) L.R. 7 HL 448, Wintle v. Nye, [1959] 1 W.L.R. 284, [1959] 1 All E.R. 552 (both decisions of the House of Lords). Fulton v. Andrews was applied in Re Timlick; Timlick v. Crawford, supra, and by the Supreme Court of Canada in Re Martin; MacGregor v. Ryan, supra. Other decisions have also applied Fulton v. Andrews and Wintle v. Nye."
The will-maker must be aware of the magnitude of the residue of her estate and must appreciate the effect of the disposition of her estate .
Faulkner v Faulkner 1920 SCC 386 seems to suggest that the test for knowledge and approval is perhaps not very high.
A lawyer prepared a will as instructed by the testator, who was fully competent when giving instructions, but when the will, so drawn was presented for execution, the will maker was not in a condition to sign his name and refused to execute it as a marksman. Three days later on the day he died, it was again presented and read over to them, clause by clause, by the lawyer who as each was read asked if he understood it, and he indicated that he did. The will was then executed by the testator, making his mark on the will with the lawyer guiding his hand, as the testator could not see.
The court held that the evidence of the lawyer and of the physician in attendance to establish that the mental capacity of the testator to follow the reading of the will, and to realize that his instructions had been carried out, had been met.
The court cited the decision of the privy Council Perera v Perera (1901) AC 354 , that stated the law, as follows:
"If a person has given instructions to a solicitor to make a will, and the solicitor prepares in accordance with those instructions, all that is necessary to make it a good will, if executed by the testator, is that he or she should be able to think thus far – I gave my solicitor instructions to prepare will making a certain disposition of my property; I have no doubt that the lawyer has given effect to my intention, and I accept the document which is put before me, as carrying it out."
Testamentary Capacity and Lay Witnesses
In a testamentary capacity case James v Field 2001 BCCA 267 recognized that the observation of a lay witness may carry as much weight as that of a doctor or other expert.
That observation was recently followed in Wilton v Koestlmaier 2018 BCSC 1257 which restated that the trial judge in his or her observations of a lay witness as to testamentary capacity, may carry as much weight as those of a doctor and referred to Re Schwartz (1970) 10 DLR (3d) 15 at paragraph 22, in which the Court of Appeal of Ontario adopted the words in Re Price (1946) 2 DLR 592 .
"The jurisprudence supports the view that the trial judge, engaged in determining whether a testator has testamentary capacity, is entitled to prefer the evidence of lay witnesses to the evidence of experts."
As was stated in Laslo v Lawton 2013 BCSC 305 at paras 198-199, testamentary capacity is not a medical diagnosis. It is a legal construct, and a court may reach a conclusion regarding the testator's capacity the conflicts with the medical diagnosis or the outcome of a medical test, including an MMSE.
Lay Witnesses Testamentary capacity
Testamentary Capacity: The Modern Restatement
The modern restatement of the test for testamentary capacity means that the will maker is sufficiently clear in his/her understanding and memory to know, on his/her own, and in a general way:
1) The nature and extent of his property;
2) the persons who are the natural objects of his bounty and
3) the testamentary provisions he is making, and he must moreover, be capable of
4) appreciating these factors in relation to each other, and
5) forming an orderly desire as to the disposition of his property.
That summary of the five factors of testamentary capacity is from Re Schwartz (1970) can DLR 15(Ont.CA), at 32 where the court provided a modern restatement of the test for testamentary capacity from the seminal case of Banks v Goodfellow (1870) LR5 QB 549.
Re Schwartz in turn was adopted by the Supreme Court of British Columbia in the decision Lazlo v Lawton 2013 BCSC 305 .
Laszlo at paragraph 189 stated that timing is the key, with there being two relevant time factors:
1) The testator must have testamentary capacity when he or she give will instructions;
2) and must have testamentary capacity when the will is executed.
The court in Lazlo went on to recognize that faltering mental capacity is prone to fluctuate and that the authorities permit variation of the degree of capacity required at these pivotal times.
For example, when a testator is competent to provide will instructions, but is not competent at the time required to execute the will, the will may still be valid so long as at the time of execution, the testator was capable of comprehending that he or she was signing a will drawn in accordance with his or her previous instructions. Re Brownhill Estate (9186) 72 NSR (2d) 181
Assessing whether a will maker possesses testamentary capacity is a question of fact and is a highly individualized inquiry.
The will maker must have had the mental capacity to appreciate and comprehend the nature and effect of the essential elements of the testamentary act, including an appreciation of the claims of persons who are the natural objects of his or her estate, as well as an appreciation of the extent of the property to be disposed.
As the Laszlo decision stated at paragraph 242, the criteria requiring the will maker to understand the nature and extent of the property being disposed of as a common area of uncertainty ( the value of one's estate). This has particularly been the case in areas like Vancouver where property values have dramatically increased for an elderly long time property owner to the point where they are almost unbelievable.
Suspicious Circumstances and Testamentary Capacity
It's important that will drafters be aware of and watch for any suspicious circumstances that might exist when taking will instructions.
Preparing a will in the presence of suspicious circumstances simply increases the risk that the wills draftsperson might end up testifying about the validity of the will in subsequent years.
The litigation issue is usually an allegation of lack of testamentary capacity when the will instructions were given and when the will was acknowledged (signed?) , both being requirements of a valid will.
The Doctrine of "Suspicious Circumstances"
In addition to testamentary capacity, the propounder of a will must establish "that the testator knew and approved of the contents thereof." With regard to this requirement, the Supreme Court of Canada in Lidstone, 1931 SCR 695
"When it has been established that a will has been duly executed by a testator having testamentary capacity, and also established that it was read by, or read over to, the testator before execution, there arises ordinarily, in the absence of suspicious circumstances, a strong presumption that he knew and approved of its contents, but there is no inflexible rule on the subject. If, however, there are circumstances which arouse the suspicions of the Court — as, for example, if the will was prepared by a person who takes a benefit under it – the party propounding the will must remove the suspicion by proving that the testator knew and approved of the contents of the document, and it is only when this has been done that the onus of proving fraud or undue influence is thrown on the opponents of the will."
The doctrine of suspicious circumstances may arise in circumstances in which the background concerning the making of the will gives rise or should give rise to some suspicion.
The doctrine is intended to ensure that there is no doubt that the making of the will was the free and voluntary act of the testator.
In dealing with the will, the Supreme Court of Canada in Vout v. Hay 1995 125 D.L.R. (4th) stated that when dealing with the doctrine of suspicious circumstances and the onus of proof, the party alleging undue influence must prove it, and the question becomes which is more persuasive: the evidence calling into question the validity of the will (the suspicious circumstances) or the evidence supporting it.
It is crucial that a will practitioner look for and identify factors which might appear to be suspicious and to ensure that there is ample evidence to override those circumstances as having had an effect on the testator, prior to the execution of the will. Again there should be a detailed record made of the practitioner's observations after "probing the mind of the potential will maker" , and the notes preserved.
A seemingly in-exhaustive short list of the innumerable circumstances which might be suspicious is as follows:
(a) where a gift is made to a person with whom the testator had a close relationship but which was not known or recognized by the testator's family;
(b) where a gift is made to a person who is in a position to influence the testator, such as a care-giver, or the worst example, the party preparing the will;
(c) where an apparently unwarranted, undeserving, or unpopular gift is made to a beneficiary who, in the minds of the those left behind, should not receive the gift;
(d) where a gift is made to a beneficiary to whom the testator has had no close relationship, such as a charity;
(e) where the division of assets among the children of the testator is substantially unequal, or a certain child or children are harshly treated;
(f) where the will substantially deviates from previous wills . Always review previous wills prior to taking instructions and having a new will executed.;
(g) where a gift is made to a person standing in a fiduciary relationship;
(h) where the beneficiary accompanies the testator on each trip to your office during the process to complete the will;
(i) where you receive the testator's instructions from someone other than the testator;
(j) where there has been a recent serious illness or hospitalization;
(k) where there is any question at all about testamentary capacity;
(l) where there are indications of alcohol abuse or medications that are potentially mind altering, being used;
(m) where there is a hasty or unwise marriage or common-law relationship;
(n) where there is evidence of depression;
(o) where there is a language/cultural disability or illiteracy;
(p) if you have been asked to prepare a will for someone by which you are to inherit, then you should ensure that the testator receives independent legal advice, and preferably take no part whatsoever in the preparation of the will.
(q) The recent widower and the young woman to inherit everything scenario
In circumstances where the testator has a will and substantial changes are being made, it would be prudent for the wills drafter to enquire of the testator as to the provisions of the previous will and the reasons for the changes.
Similarly if a child or children are being disinherited, the wills drafter should consider preparing a detailed memorandum pursuant to the provisions of the Wills Variation Act, ( now S 60 WESA) and enclosing a copy of that signed memorandum with the original will. The memorandum's facts must be accurate so that the testator is not subsequently viewed by the court as being vindictive, as opposed to objective.
Laszlo v Lawton 2013 BCSC 305
The law relating to testamentary capacity and suspicious circumstances was canvassed in Laszlo v Lawton 2013 BCSC 305.
The court recognized that faltering mental capacity is prone to fluctuate and the court authorities permit variation of the degree of capacity required at these pivotal times.
To lack of testamentary capacity does not mean that the testator must be in a perpetual state of substandard competence. Seemingly rational persons may be without mental capacity while seemingly compromised persons may possess it. It may change in fluctuate slightly or wildly so that at times a person may be of sound mind, while at other times may not be.
The Courts recognize that dementia can impair a testator's mental powers, such that he or she is not capable of making a will, however, a diagnosis of dementia, standing alone, does not automatically correspond to testamentary incapacity.
Similarly, a person who is judicially declared incapable of managing his or her affairs pursuant to adult guardianship legislation or suffers a chronic psychotic illness such as schizophrenia may still have the capacity to make a valid will.
The issue of whether a testator has the requisite capacity to make a will is a question of fact to be determined in all of the circumstances. Testamentary capacity, however, is not a medical concept her diagnosis- it is a legal construct.
Medical evidence, while important and relevant, is neither essential nor conclusive in determining the presence or absence of testamentary capacity.
Lay witnesses who have known the testator for many years can be very significant witnesses, and it is open to the court to accord greater weight to lay evidence than to medical evidence, or reject the medical evidence altogether.
The leading decision of Vout v Hay (1995) 2 SCR 876 , affirmed that the legal burden of proving due execution of the will and both testamentary capacity and that the testator knew and approved of the contents of the will is with the party propounding the impugned a will.
There is a rebuttable presumption that the testator does it stop the requisite knowledge and approval and testamentary capacity were the will was duly executed.
The Vout decision clarified that the presumption may be rebutted by evidence of well grounded suspicions, known as "suspicious circumstances" relating to one or more of the following circumstances:
1) surrounding the preparation of the will;
2) tending to call in to question the capacity of the testator;
3) tending to show that the free will of the testator was overborne by acts of coercion or fraud.
This presumption, places and evidentiary burden on the party challenging the will to induce or point to some evidence which accepted, would tend to negative knowledge and approval or testamentary capacity Vout at para. 27.
The usual civil standard of proof, namely proof on a balance of probabilities generally applies to dispelling the suspicious circumstances that have been raised. As a practical matter, the extent of proof required will be proportionate to the gravity of the suspicion, which will vary with the circumstances peculiar to each case.
The courts are clear that a general miasma of suspicion that something is unsavory may have occurred will not be sufficient. Clark v. Nash (1989) 61 DLR (4th) 409 BCCA
Suspicious circumstances exist in a wide array of situations and are not necessarily sinister in their nature. Very often a close observation and questioning of the testator will reveal one or more of a non-exhaustive list of circumstances which might give rise to being labeled suspicious circumstances and thus reversing the onus of proof in a testamentary capacity case.
Accordingly, will drafters should spend extra time questioning such a testator, and confirming records and ownership documentation in determining whether the suspicious circumstances are sufficient to question whether the proposed testator has sufficient mental capacity.
Suspicious Circumstances Testamentary capacity will will drafting
Assessing Mental Capacity: MMSE Mental Capacity Tests
MMSE mental capacity tests, also known as Mini Folstein tests are frequently used by the medical profession as a screening test in assessing mental capacity.
Lawyers frequently attempt to tender the results of the MMSE results as evidence of lack of mental capacity.
The courts have determined that such tests are simply a screening test and are not determinative of capacity – they are merely an indicator that tells a doctor as to whether a full capacity test should be made.
This is particularly the case when the test is administered on a simple occasion as it is well-known that such scores can rise or fall over a period of time.
See Lazlo v Lawton 2013 BCSC 305.
Courts can therefore reach a conclusion regarding mental capacity that conflicts with the medical diagnosis or the outcome of on MMSE or other medical test.
In Lowery v . Falconer 2008 BCSC 516 the family doctor examined the testator shortly before she signed the will and concluded that she was competent. Several months later, the doctor performed, thenE and confirmed that she was capable of managing her own financial and legal affairs.
Despite these medical findings, the court concluded that the testator lacked capacity, and set aside the will.
In Shkuratoff v Shkuratoff 2007 BCSC 1061 the court expressed apprehension about reliance on the score results of the MMSE in the absence of a robust explanation of the role that it plays in making the legal determination of testamentary capacity.
The court looked to the circumstances surrounding the assessment to determine the reliability and wait to be attached to the medical evidence.
In British Columbia Public Guardian and Trustee v Egli 2003 BCSC 1716 the court reviewed the admissibility of expert evidence to support a finding of incompetence. In the course of that review, the court noted that courts of sometimes allowed expert evidence, but have been very careful about the weight to be attached to that evidence. She cited Lynch v . Lynch estate (1993) 138 AR 41 (QB) where the court allowed counsel to lead psychiatric evidence about whether the individual was suffering from Alzheimer's disease at a particular point in time.
However, the court diminished the weight which could be attached to this evidence, noting that the circumstances of the assessments were not apparent from the record, the reasons for the doctor's conclusions were unclear, and his qualifications were unknown. Further, the judge noted that the doctor was not cross-examined on his assessment.
In Egli , the court further commented that the opinion sought to be admitted for the purpose of proving the truth of the opinions are not straightforward or mechanical observation. The opinions are psychiatric in nature. They are steeped in the expert skills of a geriatric mental health worker. They are not of kin to observation, such as blue toes. The opinions about Mr. Egli's global assessment of functioning, his scores in the various mini mental status exams, and the diagnoses of his cognitive functioning. Our subjective opinions, requiring review of information, interviews, and deliberation of the author of the opinions. The court had not heard any evidence concerning the qualifications of the individuals who made the diagnoses and cannot therefore assess the degree of reliability that should be ascribed to the opinions.
It is also to be noted that a mental capacity assessment must be done by a doctor, and the nurses not qualified. Cooper v . Cooper 2000 BCSC 1650 at paragraph 4
Lack of Capacity mental capacity Testamentary capacity
Can You Prove Mental Incapacity for a Will?
Nykoryak v Anderson 2017 BCSC 1800 is a decision that in many respects is indicative of how difficult it is to succeed in having a will set aside on the basis of lack of mental capacity.
The court found that the testator who is aged 93, when he executed his last will had sufficient mental capacity to do so, despite some underlying cognitive issues. The evidence of his doctor and the lawyer who drafted the will was accepted by the court in proving that he had testamentary capacity.
The court held that the law is clear that the issue to be decided is not whether the deceased suffered from cognitive impairment when the will was executed, but rather, whether, despite the cognitive impairment, the deceased was able to:
1) Understand the nature and effect of a will understand the extent of what was being bequeathed under the will;
2) remember the persons who might be expected to benefit under the will
3) understand the nature of the claims that may be made by a person who is excluded by the will;
4) understand the extent of what was being bequeathed under the will
The lawyer who took instructions for the will had filed an affidavit at a summary trial, hearing, setting out his discussions with the testator. It was clear that the testator could not of had the discussion he had with the lawyer, if he did not meet the foregoing criteria.
In addition, the testator's long time physician had provided an opinion in the form of an expert report that although the testator had some underlying cognitive issues at the time he executed his will, including some short-term memory loss and occasional confusion, he was nevertheless probably aware of what he was doing at the time.
The test for testamentary capacity was commented upon in Bull Estate v. Bull 2015 BCSC 136 at paragraphs 114 – 117:
114- the test for testamentary capacity is not overly onerous. Sufficient mental capacity to make a will may exist, despite the presence of cognitive deterioration, and the testator may have sufficient mental capacity even if his or her ability to manage other aspects of his/ her affairs is impaired.
115- simply having an imperfect or impaired memory does not in itself absent testamentary capacity unless it is so great as to leave no disposing memory. A disposing mind and memory is on able to comprehend of his own initiative and volition. The essential elements of the will making, property, objects, just claims to consideration, revoking of existing dispositions and the like. Moore v Drummond 2012 BCSC 1702 at 158
116- the testator should have an appreciation of the claims of the persons who are natural objects of his/her estate and the extent of his or her property of which he/ she is disposing Allart Estate v Allart 2014 BCSC 211 at para 30
117- Because testamentary capacity is a legal question, and not a medical question, a medical opinion, although valuable and relevant is not determinative of testamentary capacity Laszlo v. Lawton BCSC 305 at para 190
In the Ontario decision Birtzu v. McCron 2017 ONSC 1420 at para 40 the court stated:
40- the applicant notes that testamentary capacity is not the same thing is the capacity to manage one's property and the capacity to confer a power of attorney. I agree. This does not mean the test is higher for testamentary capacity, rather, it is different. Should this point need illustration, none better can be found, then in the decision Palahnul v Palahahnuk Estate 2006 OJ 5304 were a will made by an 80-year-old testator had been found incapable of caring for her own person or her own property. The testator was cared for by a niece, under an agreement with the public Guardian and trustee, the court found:
Testator requirements for making a valid will:
The requirements for a testator to have a sound disposing mind in order to make a valid will include the following:
The testator must understand the nature and effect of a will
The testator must recollect the nature and extent of her property
The testator must understand the extent of what she is giving under the will
The testator must remember the person she might be expected to benefit under her will
The testator were applicable must understand the nature of the claims that may be made by a person she is excluding from the will.
Establishing a lack of testamentary capacity
Isolated memory or other cognitive deficits do not establish lack of testamentary capacity.
Such things as imperfect memory, inability to recollect names and even extreme imbecility, do not necessarily deprive a person of testamentary capacity. The real question is whether the testator's mind and memory are sufficiently sound to enable him or her to appreciate the nature of the property was bequeathing, the manner of distributed and the objects of his or her bounty.
Care must be taken in reading the physicians clinical notes are in interpreting their diagnoses.
Diagnosing someone is having dementia does not necessarily mean the person is demented. Diagnosing someone is having Alzheimer's dissolving the person lacks capacity, though it may foretell a loss of capacity. If the disease progresses, as expected. Delete from an initial diagnosis to a conclusion of legal incapacity is unwarranted and very dangerous reasoning.
Cognitive Issues Impaired memory mental capacity probate Testamentary capacity Undue Influence Will Execution wills
Predatory Marriage
Probably every experienced estate litigation lawyer has had court actions involving a predatory spouse. The phenomenon is disturbing and increasingly common in our society as individuals both live longer and accumulate more wealth.
In simple terms, predatory spouses take advantage of elderly victims and assume control of their financial affairs and often culminate in a secret marriage. The consequences for the victim and their immediate family are traumatic and significant.
Predatory marriage refers to a marriage ceremony entered into for the singular purpose of exploitation, personal gain and profit. Love and personal commitment are simply not part of the equation. The relationship typically begins when a caregiver persuades a vulnerable person to marry. The victim is usually elderly, dependent, vulnerable and suffering from significant cognitive impairment.
The marriage ceremony is usually secretive and the victim is thereafter closeted away from their loved ones as the predator takes control and management of the victim's financial affairs.
Historically, the courts took an overly simplistic approach to marriage in that they equated marriage to a simple contract requiring minimal mental capacity. In other words, "any idiot can get married".
Ironically, perhaps, if the contract to enter marriage is so simple, then why does a significant percentage of the legal profession engage in full-time work trying to extricate the parties from the supposedly simple contract?
One of the early leading cases is from 1885. Durham v. Durham 10 P.D. 80 provided a quote that has been frequently adopted by Canadian courts: "the contract of marriage is a simple one, which does not require a high degree of intelligence to comprehend".
It is only in recent years that the courts have taken a more realistic approach to the level of mental capacity required to enter into a valid marriage. The law may still be described as being in a state of flux, and the courts typically still view the capacity to marry as a lower threshold than the capacity to manage one's affairs, make a will, or instruct counsel.
The leading case in British Columbia is Wolfman–Stotland v. Stotland 2011 BCCA 175, which set out the hierarchy of capacity required for various decisions, holding that:
separation is the simplest act, requiring the lowest level of understanding;
divorce, while still simple, requires a bit more understanding in that it requires the desire to remain separated and no longer be married;
American courts have recognized that the mental capacity required for divorce is the same as that required for entering into marriage;
financial matters require a higher level of understanding than marriage;
the capacity to instruct counsel involves the ability to understand financial and legal issues, which puts it significantly higher on the competency hierarchy;
the highest level of capacity is that required to make a will.
A lack of mental capacity to marry will render a marriage void ab initio (as if it had never occurred) per Ross-Scott v. Potvin 2014 BCSC 435.
The law presumes that an adult has capacity unless the contrary is established. The onus of proof for establishing lack of mental capacity to marry is on the person asserting the same.
3 Recent Cases Involving Predatory Spouses
1. Juzumas v. Baron 2012 ONSC 7220
This case involved a predatory marriage where the victim, Mr. Juzumas, was an 88-year-old vulnerable male who was mentally incompetent. The court set aside a wedding and a transfer of his property to the predator's son on the basis of the doctrines of undue influence and unconscionability.
Ms. Baron, the predator spouse, was a 64-year-old widow who had been married previously 6 to 8 times and had a history of caring for older men with the expectation of receiving an inheritance through their estates. She befriended Mr. Juzumas and promised to live together and care for him. He married her and signed a will naming her as the executrix and sole beneficiary.
After the marriage ceremony Ms. Baron continued to live in a separate apartment with her 23-year-old son and only visited her purported husband for several hours a week. She became increasingly abusive controlling and domineering towards Mr. Juzumas.
Without her knowledge, Mr. Juzumas ultimately changed his will to leave Ms. Baron only a modest bequest of $10,000. When she found out she embarked on a campaign to ensure that she received Mr. Juzumas s's home. Through the assistance of a lawyer, an agreement was drafted that transferred the property to Ms. Baron's son and Mr. Juzumas was left with a life interest in his home.
At the time of the transfer, Mr. Juzumas was 91 years of age, vulnerable, in failing health and completely dependent on and dominated by his abusive spouse. He lived in constant fear of being abandoned to a nursing home, with which Ms. Walker continually threatened him.
He commenced a court action to set aside the transfer of the property and sought a divorce and dissolution of the marriage.
The court set aside the transfer of land on the basis of the doctrines of undue influence and unconscionability, both of which may be used "where a stronger party takes advantage of a weaker party in the course of inducing the weaker party's consent to an agreement".
The court found that there was actual undue influence by reason of the fact that Ms. Baron threatened an elderly dependent with abandonment to a care home.
The court also found presumptive undue influence by reason of the fact that she was a caregiver who had the ability or potential to dominate the will of the other, whether through manipulation, coercion, or outright but subtle abuse of power.
It was incumbent upon the wife to rebut the presumption of undue influence and demonstrate that the transaction was an exercise of independent free will, which she was completely unable to do.
The court also relied upon the doctrine of unconscionability which gives the court the jurisdiction to set aside an agreement resulting from an inequality of bargaining power. The onus is on the defendant to establish the fairness of the transaction.
2. Hunt v. Worrod 2017 ONSC 7397
The facts of this case are perhaps as egregious as they possibly may be with respect to predatory marriages.
As a result of a catastrophic head injury, the 50-year-old Mr. Hunt had been in a coma for 18 days and hospitalized for four months. The injury left him with what doctors described as a wasted, shrunken brain.
Three days after leaving hospital, Mr. Hunt was spirited away by the defendant Worrod, a former girlfriend, for a secret wedding that gave her legal rights to his future wealth and his landscaping business, home and expected $1 million personal injury settlement.
Mr. Hunt's concerned children contacted the police, who located him in a motel just hours after the purported wedding took place. His sons had been made his legal guardians by court order.
Mr. Hunt never lived with his purported wife after the marriage. Before the accident he had had an on-again, off-again relationship with Ms. Worrod and had concluded their relationship with a separation agreement that resolved all of their property and legal obligations to each other. In fact, he had been required to contact the police to remove her from his residence when the relationship ended.
It was noted that Ms. Worrod was an extreme alcoholic who had hit Mr. Hunt when drunk and was generally unable to act and care responsibly for herself while intoxicated.
Evidence at trial from various medical experts was conclusive that Mr. Hunt was intellectually devastated with serious physical and cognitive issues that made him increasingly malleable and easily influenced through emotional stimulation, including sexual relations.
The medical evidence was consistent that Mr. Hunt suffered a classic case of frontal lobe syndrome that limited his ability to reason abstractly, problem solve, make decisions or consider alternatives, and that he lacked insight and self-awareness. His cognitive limitations severely limited his ability to understand the consequences of his behaviors and actions.
All of the various medical experts who testified made it clear that Mr. Hunt did not have the capacity to marry. As stated in Ross-Scott v. Potvin 2014 BCSC 435:
"A person is capable of entering into a marriage contract only if he or she has the capacity to understand the nature of the contract and duties and responsibilities it creates. The assessment of a person's capacity to understand the nature of the marriage commitment is informed, in part, by an ability to manage themselves and their affairs. Delusional thinking or reduced cognitive abilities alone may not destroy an individual's capacity to form an intention to marry as long as the person is capable of managing their own affairs."
The court concluded that Mr. Hunt did not have the requisite capacity to marry as he did not understand the nature of the contract he was entering into and the responsibilities the contract created.
The marriage was declared void ab initio and Ms. Worrod was ordered to have no further contact with Mr. Hunt.
3. Devore-Thompson v Poulain 2017 BCSC 1289
The deceased, Donna Walker, suffered from Alzheimer's disease and in September 2010 was declared by the court to be incapable of managing her financial and legal affairs because of her dementia. She had moved into a care facility in September 2010, where she remained until her death in late 2013 at age 74.
Ms. Walker had purportedly married the defendant Poulain in June 2010 but they never lived together, either before or after the marriage ceremony.
The overwhelming evidence of several lay witnesses, as well as a treating geriatric psychiatrist, was that Ms. Walker had lacked mental capacity to marry in 2010.
For example, one lay witness testified that Ms. Walker had told her that she did not know where she was married, who married her, or even why she married the defendant. Once again, the marriage was done in secret and there were no friends or family at the wedding service.
There was one photograph taken at the wedding ceremony which clearly indicated that Ms. Walker's facial expression was vacant.
After her first marriage ended, Ms. Walker had always told those close to her that she never wished to marry again. She was very close to her family and friends but never expressed to a single witness that she was in love with the defendant, that she knew anything about him, that they had any kind of future together, or that she wanted to get married and spend the rest of her life with him.
The evidence of the treating geriatric psychiatrist was most significant, in that she testified as follows:
Ms. Walker did not understand reality, absorb information or make decisions based on the correct facts, and that she had no insight or judgment.
On learning of the purported marriage, the psychiatrist had made an urgent referral to the Public Guardian and Trustee stating that Ms. Walker was incapable of entering into a marriage relationship as she was moderately to severely demented and had significant impairment of executive function. She also noted that Ms. Walker was at significant risk for abuse as a vulnerable adult.
Ms. Walker did not have a grip on reality but insisted that she was fully independent for self-care and household management, despite much evidence to the contrary.
The defendant testified that he had no concern about Ms. Walker's mental capacity.
The court had no difficulty in finding the defendant to be a completely untruthful witness who was motivated by a desire for financial gain from Ms. Walker's assets.
The court concluded that Ms. Walker's mental capacity had diminished to such an extent that she could not have formed an intention to live with the defendant or to form a lifetime bond. At the time of the marriage she did not understand what it meant to live together with another person, and could not know even the most basic meaning of marriage or understand any of its implications, including who she was married to, in the sense of what kind of person he was, what their emotional attachment was, that they would be living together, and fundamentally how marriage would affect her life on a day-to-day basis in the future.
Accordingly, the court found that Ms. Walker did not have the capacity to marry the defendant and the marriage was declared void ab initio. Two wills done by Ms. Walker in 2007 and 2009 were also set aside by reason of her lack of capacity.
The advent of a rapidly aging population with significant wealth will certainly lead to a rise in the increasingly common phenomenon of predatory marriage.
The legal issue of mental capacity to enter into such a marriage will increasingly become more relevant and litigated.
The legal test for capacity to marry is in a state of flux. It will undoubtedly continue to evolve as more instances of predatory marriage are brought before the courts and they become more accustomed to recognizing such predatory behavior.
To some extent I believe it is a situation where the courts need to be more cognizant of the significant number of predators in our society who prey upon the infirm and vulnerable.
The concept that only a low level of mental capacity is required to enter into a marriage is an anachronism that needs to be corrected, given the complexity of current family law, particularly as it relates to property entitlement to the assets of one spouse.
At present, to succeed in having a purported predatory marriage set aside, it is necessary to prove on the balance of probabilities that the victim lacked mental capacity to understand the nature of the marital contract, which typically requires both the testimony of lay witnesses and medical evidence of lack of capacity.
The Juzumas v. Baron decision is significant in that the court also invoked the doctrines of undue influence and unconscionability in setting aside the purported marriage. Hopefully it will be followed by other court decisions as useful tools to remedy a wrong suffered in the context of a predatory marriage and financial abuse.
Dysfunctional Families Media mental capacity News Testamentary capacity Undue Influence


text:
Texture.
September 30, Oregon.
Georgia.
Dylan likes Georgia a lot and I can't blame him.
September 30, Oregon, Illinois (50 miles, fairgrounds.)
Road exclamations.
September 29, Burlington.
For a while this morning I drove behind an oversize load truck.
On the oversize load banner there was, on the left-hand side, a hand pointing to the left next to the word "Passing side," and, to the right-hand side, another hand pointing to the right next to the word "Suicide" followed by three exclamation points. In between could be read: "Thank you for driving like you belong behind the wheel," with four exclamation points.
I drove as if I didn't, taking a picture.
September 29, Burlington, Illinois (69 miles, Burlington park.)
Follow-up.
September 28, Marseilles.
The case against the death penalty couldn't be better put.
Let's hope money talks, if morality won't.
School of life.
There were as many as nineteen kids traveling with the circus at some point this year but Dee Dee's classroom has now shrunk to a handful.
School takes place under the cook-house tent under rain, sun - or gale-like winds and cold. The weather report on the radio called for winds of up to sixty miles per hour today in northern Illinois, and the arrival of autumn chills; the kids were all bundled up and sipped hot chocolate to stay warm.
Dee Dee has been teaching Eric since he was five years old and freshly arrived from Brazil. He learned English with me, she said. He is now fluent in English and attends Hugo schools in the winter off-season.
Luis is the only student who doesn't speak English. He lags behind in class.
Dee Dee has no choice but to bring Sam to class as Teto is working raising the tent at the same time she teaches school every morning. Sam knows all the kids by name.
Marseilles.
We moved out of Chicagoland this morning, and into the small town where Dee Dee's grandparents lived and are buried.
Marseille is the name (the original takes no s at the end) of a major city in the south of France, by the Mediterranean, the country's foremost commercial port, immigration hotbed and its most diverse cultural melting-pot beside Paris.
One of us.
September 27, Lisle.
She left tonight after the last show.
So long Rebecca, see you down the road.
Backstage moments - mother and son.
Backstage moments - brothers.
More wings.
Sunday dinner.
Dinner is served between the shows in the circus, so on Sunday that means eating at four o'clock, before, in Patsy's case, rushing off to the office.
The custom comes from having to take down the cook house tent and clean the kitchen in time for taking down the tent after the second show. For those who don't have a private kitchen, like everyone on the crew, that means depending on the pie car, or home-made meals served by one of the families on the show, for an after-work snack at the end of the day. Josie used to do it, then Reyna when Josie was gone, but for a while now there hasn't been a pie car and the guys have to make do with gas station fare from, if they're lucky, around the corner.
Close-up.
September 27, Lisle, Illinois (24 miles, community park.)
Backstage moments - the Fernandes.
September 26, Elk Grove Village.
Backstage moments - Luawana ladies.
Backstage moments - Luawana ladies in step.
September 25, Elk Grove Village, Illinois (23 miles, 999 Leicester Road.)
Bounce flash test.
September 24, Darien.
Lamé.
Buckner.
Buckner, animal handler.
Jesus, cook.
The Rosales.
Julio and Deyanira Rosales came by for a visit today with their daughter Doricela. They are working at the Vasquez Circus and it is in the Chicago area as well these days.
I caught them as they were leaving, and the light was fast leaving too.
September 24, Darien, Illinois (6 miles, Carmelite Carefree Village.)
Legal horror.
September 23, Downers Grove.
The New Yorker gets to me late but it is still a remarkable treat.
What I read in the September 7th edition today about Todd Willingham's case made me ill and shattered the little faith I had left in the ability of this country's legal system to carry out exactly that - justice.
Fall colors.
Gallop.
Late into the morning I heard a gallop and looked out to the baseball diamond beyond our house to see Eric riding Ace, an eleven-year-old Percheron.
Last week Armando bought new horses and sent two others back to Hugo (Lucy, his mother, came up with Marcelino and dropped off Natalia and the baby too; they had left for hugo with Zefta and Renzo.)
Outtake (free-flowing.)
Musings on futility.
The only problem really with living in a small travel trailer with kids is that once they've strewn the toys all over the floor there is no space left to walk (or sit.) My days are filled with pushing toys around in a futile attempt to clear a passage for the rest of the inopportune dwellers.
I don't know why I keep doing it, other than to prove a point lost on anyone but me, a sort of Mom Maginot line; it would be easier to just skip and dodge - a principle that also applies to life in general, come to think of it.
September 23, Downers Grove, Illinois (17 miles, middle school.)
Single trapeze.
September 22, Addison.
Alberto's panaderia.
Laundry day.
As often when it's close by, half the circus was at the laundromat, before and after us.
As we headed off the lot to the laundromat next door I spotted the crew taking their morning break on the unfolded tent, a little earlier than usual.
The day is warm and muggy.
Ascencion.
Not green.
The name is ironic for there is nothing bucolic about this densely immigrant suburb of lower-end chain stores.
September 22, Addison, Illinois (28 miles, Green Meadows.)
A stroll at the mall.
September 21, Vernon Hills.
The boys and I are prisoners of the mall.
I wanted to go walk around with them in the stroller this afternoon after working on the project but soon found out there is nowhere to cross the avenue and no sidewalks either. I walked across last night going over to the grocery store but that was really jaywalking because although there are lights where traffic stops, there is no marked pedestrian paths - you're simply not supposed to be out walking.
Malls I dislike, to say the least. The enclosed space makes me claustrophobic, the array of stores dizzy, the perfumes nauseous. Add the ghastly mix of music coming out of the stores and teenagers bumping into you and I want to run for my life.
Yet to the mall we were forced to retreat, and next to the playground were three toy stores judiciously located to make me want to run faster.
Third time does it.
Perfect soft-box of a gray sky, no wind, ideal setting for an outdoor studio: the mall parking lot.
Oscar.
Steve and Aby.
Steve and Abby, his new girlfriend, aerialist.
Trapeze impromptu.
Rebecca was called upon to fill in for the Fernandes family today; Adilson doesn't feel well and they couldn't work.
She did a single trapeze act. She was nervous going in but didn't show it much.
It was awesome, she said coming out.


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