The Dismissal of Exceptions to an Estate Inventory is Not a Final Appealable Order if the Exceptor's Will Not Financially Benefit from the Discovery of Additional Assets

In re Estate of Rand, 8th Dist. App. No. 99678, 2013 Ohio 4709. A decedent's will provided specific bequests to several heirs and the remainder of his estate to an educational institution. The heirs specific bequests were easily satisfied by the decedent's substantial estate. Even though their specific bequests had been satisfied, the several heirs filed exceptions to the estate inventory, complaining that a stock transfer was improperly completed prior to the decedent's death and therefore should have been included in the estate inventory. The exceptions were dismissed because they did not have a pecuniary interest in the outcome of successfully litigating objections to the inventory. The heirs' appeal of the dismissal was also dismissed because the dismissal was not a final appealable order in that it did not affect a substantial right. A substantial right was defined as a "present interest" and an "immediate, pecuniary interest", and because the heirs admittedly did not have an immediate pecuniary interest, their appeal was dismissed.