If ever there was a god case to throw out a will for vagueness it was the will of Joseph Bisagno. Maybe the fact that a few judges stood to collect - and did collect - had something to do with the judicial effort to breath life into this open-ended will.

Joe Bisagno was born and died in San Fransisco, California, his death occurring in 1919. When he died, it was discovered that (1) his estate was worth $350,000 in 1922 dollars and; (2) it was to be divided between, quoting now from his last will and testament, "friends who have been kind to me."

It is one thing for the law to bend over backwards, as it does, and as it should, to salvage and breath life into a will which is poorly written but the law should not, ever, breath life into a will that is so fraught with vagueness as this one. What's a friend? What is kindness?

Marjorie RambeauBut it happened and it happened in San Fransisco in December of 1922, under the presidency of probate judge Robinson. Tom, Dick and Harry lined up like the poor at a food kitchen during the Great Depression. Even Broadway star Marjorie Rambeau (1889-1970; pictured) showed up at the courthouse, likely all decked out, and purring the virtues of her intimate relationship with her dear friend Joe. She got $1,400.

Even Judge James G. Quinn of Oakland got $5,600.


  • Clubman's Will Rewards 203 Who Were Kind; Judges, Actresses and Bootlacks on His List, New York Times, December 7, 1922
  • Duhaime.org, Famous Wills