Definition
In the law of testamentary construction, "medals" is a term of art used to interpret the scope of bequests. When a testator bequeaths medals, the term is construed broadly enough to pass not only decorative commemorative pieces but also curious or noteworthy pieces of current coin that the testator kept together with, or in the manner of, medals. The operative question is the testator's evident purpose in collecting and storing the items rather than the technical classification of the objects themselves.
Common Language
Modern common usage (Wiktionary): Plural of medal; metal discs or pieces typically awarded for achievement, commemoration, or military service.
Historical common usage (Webster's 1913): A piece of metal in the form of a coin, struck with a device, issued to commemorate a person, event, or achievement; distinguished from coin by not being intended as currency.
The legal gap is narrow but consequential in the testamentary context: the ordinary meaning of "medals" excludes current coin, which by common understanding is currency and not a collectible. The legal construction inverts this assumption when evidence shows the testator treated certain coins as curios alongside genuine medals, collapsing the ordinary distinction between decorative commemorative pieces and monetary coin for purposes of what passes under the bequest.
Common Confusion
Medals and coin are conceptually distinct in common usage — one is commemorative, the other is currency. In testamentary law, however, the bequest of medals may sweep in coin if the testator's collecting practice treated them as a unified category. Researchers should not assume that coin bequeathed under the label "medals" is governed by the same interpretive rules as a straightforward bequest of money or currency. Conversely, a bequest specifically of "coin" does not automatically carry medals by the same logic; the construction is asymmetric and depends on context.
Why It Matters in Research
This entry illustrates a narrow but recurring problem in historical wills and estate disputes: the imprecision of descriptive bequests of personal property collections. Researchers working with historical probate records, particularly from the eighteenth and nineteenth centuries, will encounter bequest language that uses collector's terms loosely. The Bouvier principle — that "medals" can pass curious pieces of current coin — reflects a broader judicial tendency in that period to give effect to a testator's evident intent rather than to constrain a bequest by the strict technical meaning of the descriptive word used.
A researcher tracing a disputed bequest in historical sources should check whether the estate inventory treated medals and coin as co-mingled. If the inventory separates them into distinct categories, the argument for inclusion weakens. If they appear on the same shelf or in the same cabinet, courts historically were more willing to apply the broader construction.
The Bouvier citation to 8 Atk. 202 points to Atkyns' Chancery Reports, an eighteenth-century English equity reporter, meaning this rule has English common law origins and filtered into American practice through reception of English equity doctrine. Researchers working in American jurisdictions should consider whether the local probate court accepted English Chancery principles and at what date.
Historical Dictionary Support
Bouvier's is the sole historical dictionary source for this entry and provides a concise statement of the rule: a bequest of medals will pass curious pieces of current coin kept by the testator with his medals, citing 8 Atk. 202 and Williams on Executors. The principle is narrow and context-dependent. Bouvier does not elaborate on what makes a coin "curious" for this purpose, nor does he address whether the rule applies symmetrically (i.e., whether a bequest of "coin" could carry medals). The entry is better understood as a reminder to look at the testator's actual collecting practice than as a bright-line rule. Historical dictionaries beyond Bouvier do not meaningfully address this term in a legal context, which underscores that its legal significance is essentially confined to testamentary construction.
Jurisdictional Note
The underlying doctrine derives from English Chancery equity and was absorbed into American probate practice, but modern American courts rarely encounter bequest disputes phrased in these terms. Where such disputes arise today, courts apply the general principle of testamentary intent and may not specifically follow the Bouvier formulation. Researchers in civil law jurisdictions will find no direct analog.