Justia Trusts & Estates Opinion Summaries

A nonprofit organization, dedicated to supporting children with cancer, constructed several buildings on land owned by a married couple. The couple later decided to sell the property as part of their divorce. During the process, the nonprofit was misinformed by the couple, who were also involved in the nonprofit’s board, about the value of its buildings and the contents of an appraisal report. Acting on these representations, the nonprofit agreed to accept a fixed percentage of sale proceeds. It was only after the sale closed that the nonprofit discovered the buildings had been undervalued and that the appraisals had, in fact, specified higher values for the structures.The nonprofit sued the couple in the District Court of the Seventh Judicial District of Idaho, asserting claims of constructive fraud, breach of fiduciary duty, and unjust enrichment. The district court ruled in favor of the nonprofit, finding the couple liable but reduced the damages by 50% based on comparative negligence and failure to mitigate damages. It denied attorney fees and prejudgment interest to both parties. After the nonprofit satisfied the judgment, it appealed the damage reduction and denial of fees, while the couple cross-appealed on several grounds, including the application of the election-of-remedies doctrine, various defenses, and the finding of fiduciary breach.The Supreme Court of the State of Idaho held that the election-of-remedies doctrine did not bar the nonprofit’s appeal. It found the district court erred in reducing the damage award by applying comparative negligence and the duty to mitigate, as those doctrines did not apply to the equitable and fiduciary claims at issue. The Supreme Court affirmed the district court’s rulings on the other affirmative defenses, the finding of fiduciary breach, and the denial of prejudgment interest. The court remanded for entry of a judgment for the full damages and for reconsideration of prevailing party status and attorney fees, awarding the nonprofit its appellate costs. View "Camp Magical Moments, Cancer Camp for Kids, Inc. v. Walsh" on Justia Law

Two siblings became involved in a dispute over the ownership and management of their late father’s interest in Tautphaus Park Storage, LLC (TPS) and the administration of his estate. The sister, an attorney, had acted as their father’s lawyer, power of attorney, and later as personal representative of his estate. After their father’s death, she executed amendments to TPS’s operating agreement that shifted ownership and control of the company to herself, some of which were made retroactive. The brother contended that these amendments were improper and that his sister had diverted assets that should have been part of the estate. He sought judicial determination of the estate’s assets and claimed breach of fiduciary duty, among other causes of action.The litigation proceeded through both a magistrate court probate proceeding and a separate district court action under the Idaho Trust and Estate Dispute Resolution Act (TEDRA). There was confusion over whether the cases were consolidated, and repeated disputes about discovery, particularly concerning access to TPS’s business records. The magistrate court dismissed the brother’s claims against the sister and TPS, reasoning in part that certain claims belonged exclusively in probate and that TPS and the sister in her individual capacity were not necessary parties. The district court affirmed these dismissals, concluding the claims for judicial determination of the estate and breach of fiduciary duty were matters for the probate court alone.The Supreme Court of the State of Idaho reviewed the case. It held that the brother’s claims for judicial determination of the estate and breach of fiduciary duty fell within TEDRA’s scope and could be brought as a separate civil action, not confined to probate. The Court further held that the sister was a necessary party and TPS was a proper nominal party to the TEDRA action. The Court vacated the judgments of the magistrate and district courts, reversed the orders dismissing parties and claims, and remanded for further proceedings. The brother was awarded costs and attorney fees on appeal against the sister personally. View "Monson v. Monson" on Justia Law

A dispute arose among family members who owned and operated a car dealership in West Virginia following the distribution of shares from a trust created by their late mother. One sibling, who received a minority share of the company, brought suit against her relatives, including her sister, brother-in-law, nieces, and one niece’s husband, all of whom held various positions in the dealership. She alleged that several of them, acting in concert, breached fiduciary duties, engaged in negligence, tortiously interfered with her inheritance, and committed related wrongful acts, including civil conspiracy, to benefit themselves at her expense.The Circuit Court of Raleigh County granted partial motions to dismiss some claims against certain defendants with prejudice. Notably, it dismissed all claims against one defendant, Mr. Hopkins, and removed him from the action with an express statement that this dismissal was “final.” The plaintiffs appealed these dismissals to the Intermediate Court of Appeals of West Virginia. The Intermediate Court reinstated the civil conspiracy claim against Mr. Hopkins, finding it was sufficiently pled, and reinstated certain claims against other defendants, but did not address whether the order was final as required for appellate review.The Supreme Court of Appeals of West Virginia reviewed whether the Intermediate Court had proper appellate jurisdiction under the finality requirements of West Virginia Code § 58-5-1 and Rule 54(b) of the West Virginia Rules of Civil Procedure. The Supreme Court held that the Intermediate Court lacked jurisdiction to review the interlocutory dismissals against Ms. Abrams and Mrs. Hopkins, vacating its decision as to them. However, the Court found the dismissal order as to Mr. Hopkins was sufficiently final to be appealable, affirmed reinstatement of the civil conspiracy claim against him, and remanded for further proceedings. View "Hopkins v. Sutphin" on Justia Law

After the death of Harry Fairhurst in 2019, his will—executed in 1981 with a 1997 codicil—left his estate equally to his seven children and named two of them as co-executors. The main asset was the family home. The will allowed the co-executors to sell estate assets without probate court approval, provided all children were notified by mail of their option to purchase. In 2020, the co-executors notified the devisees that the property was available, but the letter omitted key sale terms. No child responded. Subsequently, William, one of the co-executors, purchased the property for $260,000, using part of his share as an advance toward the purchase price, despite a higher bank appraisal and market analysis.Three siblings objected to the accounting of the sale in Cumberland Probate Court, focusing on the valuation and terms. The probate court, without hearing argument, found the sale invalid and illegal because the co-executors had not sought probate court approval, as required by Rhode Island General Laws § 33-19-9. The property was ordered to remain with the estate. The co-executors appealed to Providence County Superior Court, arguing the will authorized the sale without court approval and that the probate court’s sua sponte action violated their due process rights. Both sides moved for summary judgment.The Supreme Court of Rhode Island reviewed the case on appeal. It held that, regardless of the will’s language, § 33-19-9 required probate court approval for a co-executor’s private purchase of estate property to prevent self-dealing and ensure fairness. The Court found the will’s contrary provision invalid to the extent it conflicted with the statute and rejected the co-executors’ due process and laches arguments. The Supreme Court affirmed the Superior Court’s judgment, upholding the voiding of the sale. View "Fairhurst v. Fairhurst" on Justia Law

This case involves a dispute over the management and succession of a living trust established by the stepfather of Mitchell D. Brown and Tina J. Bowden. Brown alleged that Bowden, while serving as trustee, breached fiduciary duties, amended the trust improperly to appoint Diahanne L. Morse as successor trustee, and engaged in self-dealing. After Bowden’s death, Morse acted as both the representative of Bowden’s estate and as the purported trustee. Brown sought damages, declaratory relief to void Morse’s appointment, and the naming of an independent trustee. Morse denied the allegations and brought counterclaims for tortious interference and slander of title related to trust property.The Waldo County Superior Court granted Brown’s motion to amend his complaint to add claims against Morse personally and for declaratory relief. Later, the court entered partial summary judgment for Brown, declaring that he was the properly nominated trustee and that the attempted amendment appointing Morse was void. Brown voluntarily dismissed several claims without prejudice, and the court denied Morse’s motion to dismiss for lack of subject-matter jurisdiction. The court then purported to enter “final judgment,” declaring the prior summary judgment to be final and dismissing remaining claims as moot, but did not address all outstanding claims.The Maine Supreme Judicial Court reviewed the case and determined that the Superior Court’s order was not a final judgment because it did not resolve all claims in the amended complaint or all of Morse’s counterclaims. The Court dismissed Morse’s appeal as interlocutory, finding that none of the recognized exceptions to the final judgment rule applied. The Court also denied Brown’s request for sanctions. The case will remain in the Superior Court until all claims are fully resolved. View "Brown v. Morse" on Justia Law

A man named Bradley died without a will, leaving behind his wife, Rebecca, and his son from a previous marriage, Jason. Before his death, Bradley withdrew $80,000 from a savings account and used it to purchase a cashier’s check made payable to himself. Rebecca was an authorized signer on the account but was not designated as a beneficiary. After Bradley’s death, Rebecca discovered the existence of the cashier’s check, and, based on advice from a bank employee and her attorney, she deposited the funds into her personal account, believing the money was hers and not part of the estate. Jason, however, argued that the funds should belong to the estate for distribution according to the intestacy laws.The Eighteenth Judicial District Court, Gallatin County, heard the dispute. The parties agreed to submit the issue of ownership of the $80,000 to the court without further testimony. The District Court concluded that the funds were Rebecca’s individual property, finding that Bradley intended to make a gift to her and that she was entitled to enforce the cashier’s check as a holder under Montana’s Uniform Commercial Code. The court reasoned that there was clear and convincing evidence of Bradley’s donative intent and constructive delivery of the check to Rebecca.On appeal, the Supreme Court of the State of Montana reversed the District Court’s ruling. The Supreme Court held that the record did not establish a completed inter vivos gift of the $80,000 to Rebecca, as there was no evidence of donative intent, delivery, or acceptance. The court also determined that Rebecca’s status as an authorized signer did not give her ownership rights and that she was not a holder or otherwise entitled to enforce the cashier’s check. The Supreme Court ordered that the funds be treated as an asset of Bradley’s estate and remanded for further proceedings consistent with this holding. View "in re Estate of B. Haler" on Justia Law

Cynthia Miles, a sixty-four-year-old woman suffering from acute psychosis and a history of suicidal ideation, experienced several psychiatric crises in 2021. After multiple hospitalizations and escapes from care facilities, she was admitted to Harbor Point, an unlocked mental health facility, where she again escaped on November 11, 2021. Despite a search, Miles was never found. Her family, having previously experienced her disappearances followed by safe returns, could not determine her fate. After extensive efforts to locate her failed, her family petitioned the Iowa District Court for Pottawattamie County for a judicial determination of death. Following a jury trial, the court issued a certificate of presumed death on August 29, 2022.Subsequently, Miles’s daughter, as administrator of her estate, filed a wrongful death lawsuit against several healthcare providers. The defendants asserted that the action was time-barred under Iowa’s two-year statute of limitations for wrongful death claims, arguing that the limitations period began either at Miles’s disappearance or when the family first sought a declaration of death. The Iowa District Court for Cass County rejected this argument, ruling that the statute of limitations began only upon the judicial declaration of death, not the earlier disappearance.The Iowa Supreme Court reviewed the interlocutory appeal to determine when the limitations period commenced. The court held that, in a case where there is no known physical injury and it is unclear whether the missing person is alive or dead, the statute of limitations for a wrongful death claim does not begin to run until there is a judicial determination of death. The court affirmed the district court’s ruling, allowing the wrongful death action to proceed as timely filed. View "Schneide v. Holliday" on Justia Law

A company was the beneficiary of life insurance policies held in a trust formed by Daniel Carpenter. After the insurer paid proceeds to the trust, the beneficiary sought to recover the full amount and alleged that Carpenter hid assets through hundreds of shell companies. Carpenter was convicted of fraud, and the beneficiary obtained a judgment in the United States District Court for the Southern District of New York, later registering the judgment in the United States District Court for the Western District of Oklahoma. That court entered judgment against several Carpenter entities, including a limited liability company that owned another company incorporated in Oklahoma. A receiver was authorized to preserve the assets of the debtor company.An entity called Phoenix Charitable Trust, apparently linked to Carpenter, entered the Oklahoma proceedings as an “interested party” through its counsel, who had represented Carpenter and related entities in other courts. Phoenix objected to several orders issued by the district court: an award of attorney fees and costs against Carpenter, an order authorizing the sale of the Oklahoma company’s insurance portfolio, and an order denying Phoenix’s motion to vacate a prior injunction against Carpenter and his entities.On appeal, the United States Court of Appeals for the Tenth Circuit considered whether Phoenix had standing to challenge these orders. The court found that Phoenix failed to demonstrate it was injured by the attorney fees order or the sale-of-assets order, as required for Article III standing. Regarding the injunction, the court concluded that Phoenix lacked prudential standing because it was asserting the rights of others rather than its own. The Tenth Circuit dismissed the appeal for lack of standing and did not reach the merits of Phoenix’s challenges. View "Universitas Education v. Phoenix Charitable Trust" on Justia Law

The case involves disputes among the descendants of Roy and Grace Whittenburg, who were beneficiaries of separate trusts holding interests in a large ranch spanning New Mexico and Colorado. After years of litigation over the ranch’s ownership, the parties signed two settlement agreements: a Partial Settlement Agreement (PSA) and a later Compromise Settlement Agreement (CSA). These agreements were intended to resolve their disputes, with provisions for partitioning the ranch and a clause designating Texas as the forum for enforcement. When the parties could not agree on partitioning, a group led by Angela Kate initiated partition proceedings in New Mexico, as allowed by the agreements. Another group, led by John Burk, opposed the partition, resulting in protracted litigation and additional attorney’s fees.The 251st District Court of Randall County, Texas, after a bench trial, found John Burk had breached the settlement agreements by opposing the partition in the New Mexico litigation, causing Angela Kate to incur $216,112 in extra attorney’s fees. Despite these findings, the trial court entered a take-nothing judgment, holding that the attorney’s fees from the New Mexico litigation were not recoverable as damages. The Court of Appeals for the Seventh District of Texas affirmed, reasoning that the American Rule barred recovery of such fees as damages for breach of contract.The Supreme Court of Texas reversed the Court of Appeals. It held that the American Rule does not bar recovery of attorney’s fees incurred in prior litigation as damages for breach of a settlement agreement, provided the breach was not itself the basis for that prior litigation. Because the fees at issue resulted from litigation initiated before John Burk’s breach, Angela Kate was entitled to recover those excess fees as actual damages. The Court also held she could seek reasonable attorney’s fees for the Texas suit, remanding for reconsideration of the appropriate amount. View "WANG v. WHITTENBURG" on Justia Law

Two brothers became parties to a dispute over the inheritance of their father’s estate after the father died intestate. One brother, Christopher, asserted that his sibling, Daniel, was not the biological child of their father, Ernest, and therefore not entitled to inherit. Christopher petitioned for letters of administration in the probate court, claiming to be Ernest's sole heir. The probate court granted him letters of administration. Christopher then sought to remove the estate administration to the circuit court, filing a petition that was not verified under oath as required by Alabama law. The circuit court entered an order removing the administration and later, based on DNA evidence, an affidavit from the mother, and Daniel’s marriage certificate, declared that Daniel was not Ernest’s biological child or heir.After the circuit court’s order, Daniel filed a postjudgment motion arguing that the removal of the estate administration was invalid because Christopher’s initial removal petition was not sworn, as required by Ala. Code § 12-11-41. Around the same time as the hearing on this motion, Christopher submitted an amended, sworn petition for removal, and the circuit court then entered a new order granting removal. However, this action occurred after the circuit court had already issued its prior order resolving the inheritance dispute.The Supreme Court of Alabama held that the circuit court’s jurisdiction over the estate administration was not properly invoked until a sworn petition was filed, as mandated by statute. Thus, the July 2025 order declaring Daniel not an heir was void due to lack of subject-matter jurisdiction at the time it was entered. The Supreme Court of Alabama reversed the circuit court’s order and remanded the case with instructions to vacate the July 2025 order. View "Thomas v. Thomas" on Justia Law