Estate of McGovern v. Commonwealth, State Employees' Retirement Board

517 A.2d 523 · Supreme Court of Pennsylvania · 1986

Facts

Francis McGovern selected retirement options, including a joint survivor annuity for his terminally ill wife, shortly before both died. His son challenged the selection, arguing McGovern lacked mental capacity due to alcoholism and denial of his wife's illness. The Board found him competent, but the Commonwealth Court reversed.

Issue

Did the Commonwealth Court apply the correct standard of review for the administrative agency's findings and correctly state the law regarding mental capacity to enter into a contract?

Holding

The Supreme Court reversed the Commonwealth Court, reinstating the Board's decision. It held that the Commonwealth Court applied an improper standard of review and erred in adopting Section 15 of the Restatement (Second) of Contracts for mental capacity.

Rule

The proper standard of review for administrative agency adjudications is whether findings of fact are supported by substantial evidence. Under Pennsylvania common law, an adult is presumed competent to contract, requiring clear, precise, and convincing evidence of inability to comprehend the transaction at the time of execution, not mere mental weakness or an unreasonable disposition.

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Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.