The orphans' court then ordered Appellants to sign, but they again refused. They appealed to the Court of Special Appeals, which affirmed the order of the orphans' court. Allen v. Ritter, 196 Md.App. 617, 632, 10 A.3d 1183, 1191–92 (2010). We granted certiorari.

The problem with Ruby's argument is that the relevant legislative history and caselaw indicate that the General Assembly did not intend the definition of "property" contained in Est. & Trusts § 1-102(r) to mean what she asserts it does. What are now Titles 1 through 11 of the Estates and Trusts Article were first enacted in 1969 as Article 93 of the Maryland Code. Allen v. Ritter , 196 Md. App. 617, 626–27, 10 A.3d 1183 (2010). Article 93 was passed as a result of recommendations made to the General Assembly by the Governor's Commission to Review and Revise the Testamentary Law of Maryland.

The orphans' court then ordered Appellants to sign, but they again refused. They appealed to the Court of Special Appeals, which affirmed the order of the orphans' court. Allen v. Ritter, 196 Md. App. 617, 632, 10 A.3d 1183, ______ 2010). We granted certiorari.

Granted May 20, 2011. Reported below: 196 Md.App. 617, 10 A.3d 1183. Petitions For Writ of Certiorari granted.

The Court's reasoning in Faller was applied by this Court in Saggese v. Saggese, 15 Md.App. 378 (1972) (holding that a spouse waived her right to rescind a marital separation agreement on the basis of "duress, undue influence, oppression and other See, e.g., Piper Rudnick LLP v. Hartz, 386 Md. 201, 222 (2005); Allen v. Ritter, 196 Md.App. 617, 626-27 (2010), aff'd, 424 Md. 216 (2011). inequitable conduct" because the spouse waited for approximately two years before challenging the validity of the agreement). The Supreme Court of Maryland reached a similar conclusion in Adamstown Canning:

Allen v. Ritter, 196 Md.App. 617, 625 (2010) (parallel citations omitted), aff'd on othergrounds, 424 Md. 216 (2011).

The events that led to the 1969 recodification have been discussed on several occasions by Maryland's appellate courts. See, e. g. Piper Rudnick LLP v. Hartz, 386 Md. 201, 222-24 (2005); Allen v. Ritter, 196 Md.App. 617, 626-27 (2010); see also Shale D. Stiller and Roger D. Redden, Statutory Reform in the Administration of Estates of Maryland Decedents, Minors and Incompetents, 29 MD. L. REV. 85 (1969).

The Commission was established in 1965 for the purpose of making recommendations to the General Assembly regarding Maryland's inheritance tax, probate and testamentary law. See Piper Rudnick LLP v. Hartz, 386 Md. 201, 222 (2005); Allen v. Ritter, 196 Md. App. 617, 626-27 (2010), aff'd, 424 Md. 216 (2011). The Henderson Commission's story is told in greater detail in Shale D. Stiller and Roger D. Redden, Statutory Reform in the Administration of Estates of Maryland Decedents, Minors and Incompetents, 29 Md. L. Rev. 85, 87-88 (1969).

On appeal from a final judgment of an orphans' court, "the 'findings of fact of an orphans' court are entitled to a presumption of correctness.'" Allen v. Ritter, 196 Md. App. 617, 625, 10 A.3d 1183, 1187-88 (2010), aff'd, 424 Md. 216, 35 A.3d 443 (2011). Appellant contends that Vincent was removed solely because of a perceived conflict between his assertion of property interests arising pre-death in what had been Mr. Fava's Bank of America checking account and his T-bill account and his duties as Personal Representative to maximize the estate's assets, which presents a question of law (see fn. 1 supra at 1) for this Court to decide de novo.

Maryland courts have often entertained appeals from orphans' court orders pertaining to the distribution of estate assets without expressly explaining why those orders qualify as final judgments. E.g. Knight v. Princess Builders, Inc., 393 Md. 31, 38-39 (2006) (describing appeal from order directing personal representative to sell estate property as an appeal from a "final judgment"); YIVO Inst. for Jewish Research v. Zaleski, 386 Md. 654, 662 (2005) (describing appeal from denial of petition for personal representative to make a distribution as an appeal from a "final judgment"); Carrier v. Crestar Bank, N.A., 316 Md. 700, 711 (1989) (citing CJP § 12-501 as the statutory basis for an appeal from an order striking a party's exceptions to a proposed distribution); Simpson v. Piscano, 288 Md. 560, 564 (1980) (considering appeal from orphans' court order determining that the personal representative should distribute estate to some heirs to exclusion of others); Allen v. Ritter, 196 Md. App. 617, 625 (2010) (describing appeal from order requiring beneficiaries to sign releases prior to distribution of estate funds as an appeal from a "final judgment"); Segal v. Himelfarb, 136 Md. App. 539, 541-42 (2001) (considering appeal from order "pertaining to the distribution of assets," in which the orphans' court determined that assets must pass to decedent's heirs rather than to the contingent beneficiaries of the will); Willoner v. Davis, 30 Md. App. 444, 445, 449 (1976) (considering appeal from order regarding distribution of estate among biological and adopted children of decedent). Mr. Cullen has identified no authority that would undermine the proposition that an order directing a personal representative to distribute estate property is a "final judgment of an orphans' court" under CJP § 12-501.