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

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

Facts

Francis J. McGovern selected retirement options for his terminally ill wife, who died shortly after, followed by his own death. His son challenged the selection, arguing McGovern lacked mental capacity due to alcoholism and denial, as the chosen options resulted in a significantly smaller payout to the estate. The Board found him competent, but the Commonwealth Court reversed.

Issue

Did the Commonwealth Court apply the correct standard of review for the administrative board's findings of fact, and was its adoption of Restatement (Second) of Contracts § 15 for mental capacity legally sound under Pennsylvania law?

Holding

The Supreme Court reversed the Commonwealth Court, reinstating the Board's determination. It held that the Commonwealth Court applied an improper standard of review and erred by adopting a new definition of mental capacity from the Restatement.

Rule

The proper standard of review for administrative agency findings is whether they are supported by substantial evidence. Under Pennsylvania common law, mental capacity to contract requires the ability to comprehend the transaction, and mere mental weakness or an "unreasonable" disposition does not prove incompetence.

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Case brief last reviewed 2026-04-28. Prepared by CaseReader from the published opinion.