Justia Trusts & Estates Opinion Summaries

The case involves the family of a deceased inmate who alleged that certain medical professionals and a health services foundation, after performing an autopsy at the request of correctional authorities, removed and retained the decedent’s organs without family consent. The family contended they were not informed or asked for permission regarding the autopsy or retention of organs, and only learned the organs were missing when preparing the funeral. They claimed to have relied on statements from hospital staff that such practices were standard, and only discovered in December 2023, through media reports, that retention of organs without next-of-kin consent was allegedly unlawful.The Montgomery Circuit Court reviewed and denied the defendants’ consolidated motion to dismiss, finding that statutory limitations could be tolled due to alleged fraudulent concealment. The court determined that the amended complaint sufficiently alleged facts that, if proven, could justify equitable tolling under Alabama law, and that the family’s claims were not time-barred because they filed suit within two years of learning the alleged conduct was illegal.On review, the Supreme Court of Alabama considered a petition for writ of mandamus by the University of Alabama Health Services Foundation and Dr. Stephanie Reilly. The Court held that mandamus relief was appropriate because, from the face of the complaint, the claims were barred by applicable statutes of limitations. The Court reasoned the causes of action accrued by November 6, 2021, when the family learned the organs were missing, and rejected arguments for tolling or for treating the alleged conduct as a continuous tort. The Court distinguished between statutes of limitations governing different claims, and found that all claims against the petitioners except the AUAGA claim were time-barred. It therefore granted the petition and directed dismissal of all claims against the petitioners except for the AUAGA claim. View "Ex parte University of Alabama Health Services Foundation" on Justia Law

A woman, Susan, was one of three beneficiaries of her father Warren’s trust. She believed the trust’s terms were unfair to her compared to her brothers, David and Michael, as her share was subject to restrictive terms and higher taxes. Warren allegedly wanted to amend the trust to make distributions equal among his children, and had consulted an attorney about this. Susan claimed that David and Michael undertook several actions in 2021 to prevent Warren from making this amendment, including interfering with his lawyer, making accusations against Susan, and isolating Warren.Previously, Susan filed a probate petition in Alameda County Superior Court, seeking to remove David as trustee and as Warren’s agent, and alleging elder isolation and similar misconduct by her brothers. The probate petition raised many of the same factual allegations later made in this civil case. After Warren’s death, Susan dismissed her probate petition without prejudice. She then filed a civil complaint, asserting claims for intentional interference with expected inheritance (IIEI) and elder financial abuse. The elder abuse claim was later dismissed, and the IIEI claim proceeded. David filed a demurrer, arguing Susan had an adequate remedy in probate, among other defenses.The California Court of Appeal, First Appellate District, Division Four, reviewed the case after the trial court sustained the demurrer without leave to amend and dismissed Susan’s complaint. The appellate court held that Susan’s IIEI claim could not proceed because she had an adequate remedy in probate. The court reasoned that the tort of IIEI is only available when probate does not provide a remedy, and Susan, as a beneficiary, had standing and the ability to seek relief in probate but chose to dismiss her petition. The judgment dismissing the complaint was affirmed. View "Halperin v. Halperin" on Justia Law

A man and woman who had been in a relationship for five years were married in a ceremony on a dock, officiated by a minister, with only the groom’s minor son physically present at the ceremony. Two adults had previously signed the marriage license as witnesses, but only one of them was arguably present nearby in a vehicle; the other was definitely absent. After the ceremony, the marriage license was properly filed and accepted by the state. The couple lived as husband and wife until the groom’s unexpected death five months later. Following the death, a dispute arose between the widow and the decedent’s father, who acts as personal representative of the estate, regarding the decedent’s property and home.The decedent’s father sought a declaratory judgment in the Court of Chancery of the State of Delaware, arguing that the widow was not the decedent’s legal spouse because the marriage was not solemnized in the presence of two reputable adult witnesses as required by statute. He contended this failure rendered the marriage void, and sought to prevent the widow from inheriting. The Court of Chancery treated this as a petition for annulment under the Delaware Divorce and Annulment Act, but denied relief, finding that the petitioner lacked standing to seek annulment after the decedent’s death and that minor defects in solemnization do not necessarily void a marriage.On appeal, the Supreme Court of the State of Delaware reviewed the statutory requirements for marriage and found that, despite the absence of one adult witness, the parties had intended a lawful marriage and acted in good faith. The court held that the witness requirement is directory, not mandatory, and the marriage was not void for lack of a witness. The court affirmed the judgment below, holding that the marriage was valid and the petitioner could not seek its annulment. View "Lafon v. Felmlee" on Justia Law

After the death of his father, Richard, the plaintiff, Rich, brought suit against his stepbrother, Tim, and his stepmother, Patti, regarding the management of Richard’s IRA funds. Richard had named Rich and Patti as the primary beneficiaries of his IRA, with 75% and 25% interests, respectively. When Richard’s health declined due to dementia, Tim obtained a power of attorney and was later appointed conservator by an Iowa state court, but Rich was not notified of these proceedings. Tim subsequently withdrew funds from Richard’s IRA, transferred assets between brokerage accounts, and, after Richard’s death, facilitated distributions to Patti. Rich alleged he was not informed about these transfers and was unable to access his inherited share for several months, during which time the funds lost value.Following a three-day trial in the United States District Court for the Northern District of Iowa, a jury found in favor of Rich on claims of fraud and conversion against Tim and unjust enrichment against both Tim and Patti, but found no liability on certain other claims. The jury awarded compensatory and punitive damages. Both parties filed post-trial motions. The district court declined to give a jury instruction on undue influence, reasoning that the evidence did not support such a claim, and amended the judgment to prevent duplicative recovery by making Tim and Patti jointly liable for part of the award.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. It held that the refusal to instruct the jury on undue influence was not an abuse of discretion, given the record and Iowa law. The appellate court also upheld the district court’s decision to amend the judgment to avoid double recovery. Furthermore, it rejected Tim’s argument that there was insufficient evidence to support the fraud verdict, concluding that the jury’s findings of justifiable reliance and damages were supported by the trial record. View "Jeffery v. Townsend" on Justia Law

A businessman and rancher in South Dakota, after dating a Colorado horse breeder for nearly a year, proposed marriage. Shortly before the wedding, he presented her with a prenuptial agreement drafted by his attorney. The agreement waived her right to any share of his estate after his death. The parties signed the agreement at the attorney’s office minutes before their civil ceremony. They were later married in Italy and had two children. The businessman died approximately eight years later. The surviving spouse then petitioned for an elective share of the estate and a family allowance, claiming her signature on the agreement was involuntary and the agreement was unconscionable.The Fourth Judicial Circuit Court of Dewey County, South Dakota, held a trial on her petition. The court granted her request for a family allowance but denied her petition for an elective share. The court found she voluntarily signed the agreement and that it was not unconscionable, emphasizing her education, business experience, and opportunity to review the agreement or consult independent counsel. The court also found that the financial disclosures provided were fair and reasonable, and that the terms of the agreement, including a provision for her in the event of divorce, were not disproportionate or unjust. Stephanie appealed the denial of her elective share.The Supreme Court of South Dakota reviewed the case and affirmed the lower court’s decision. The Court held that the prenuptial agreement was voluntarily executed and was not unconscionable under South Dakota law. It found no clear error in the circuit court’s factual findings and determined that the financial disclosure and circumstances surrounding execution of the agreement satisfied statutory requirements. The Supreme Court affirmed the validity and enforceability of the prenuptial agreement and the waiver of the elective share. View "Estate Of Webb" on Justia Law

Tony petitioned for formal probate of his mother Judith’s will and codicil, which left her entire estate to him and specifically disinherited her other children, Rick, Sandy, and Beth. The siblings objected, alleging that the will was the product of undue influence, among other claims. The dispute centered on family dynamics and prior business conflicts between Tony and Rick, including previous litigation over property and asset division. In the prior case, the court made adverse findings about Tony’s credibility and honesty regarding his dealings with Rick.The siblings, as respondents, successfully moved in the Circuit Court of the Sixth Judicial Circuit, Todd County, for the admission of the prior court’s findings and conclusions under the doctrine of collateral estoppel, arguing these were relevant to the undue influence claim. The circuit court admitted almost all of the findings from the prior case as conclusively established, including negative credibility determinations about Tony. The jury in the undue influence trial was instructed to accept these findings as true, and ultimately found that Tony had unduly influenced Judith, invalidating the will.On appeal, the Supreme Court of the State of South Dakota reviewed whether the circuit court properly applied collateral estoppel. The Supreme Court held that the circuit court erred by admitting the prior findings wholesale, as the issues in the prior litigation were not identical to those in the undue influence case and the credibility determinations were not essential to the prior judgment. The Supreme Court found this error was prejudicial, as it likely impacted the jury’s assessment of Tony’s credibility, a central issue in the undue influence claim. The judgment was reversed and the case remanded for a new trial. View "Estate Of O'Neill" on Justia Law

After the death of Glenna Mae Wylie-Nelson, her Last Will and Testament devised her home and two lots to her son Leslie H. Wylie, but reserved a life estate for her husband, Larry T. Nelson. The Will also provided that if Larry and Leslie agreed to sell the property during Larry’s lifetime, Leslie would receive the first $40,000 from the sale and the remaining proceeds would be split equally. Larry claimed that community property funds were used for maintenance and improvements on the property during his 35-year marriage to Glenna Mae and sought compensation for the increase in property value attributable to these efforts.While Glenna Mae’s estate was being probated in the Magistrate Court of Bonner County, Larry filed a petition under the Trust and Estate Dispute Resolution Act (TEDRA) in the District Court of the First Judicial District. He sought a judicial declaration of his rights in the property and compensation for his claimed community property interest. Respondents, including Leslie and the estate’s co-personal representatives, moved to dismiss the petition, arguing lack of jurisdiction and failure to state a claim. Larry attempted to amend his petition to clarify his claims and remove his request for partition by sale. The district court dismissed the petition for lack of jurisdiction under TEDRA, denied leave to amend, and awarded attorney fees to the Respondents.The Supreme Court of the State of Idaho reviewed the case de novo. It held that TEDRA provides district courts with broad subject matter jurisdiction over estate and trust matters, including Larry’s claims for declaratory relief regarding his interest in property passing at death. The Supreme Court vacated the district court’s judgment, reversed its orders denying leave to amend and awarding attorney fees, and remanded for further proceedings. Larry was awarded costs on appeal. View "Nelson v. Wylie" on Justia Law

This case concerns a dispute among siblings regarding the partition of farmland in Grant County, North Dakota, originally owned by their parents. After the parents conveyed the land to their children as tenants in common, reserving life estates, four siblings transferred their interests into a family trust in 2017, leaving Bryan Tischmak as the sole sibling outside the trust. In 2022, the trust entered into an agreement for rock, sand, and gravel extraction on portions of the property. Bryan initiated a partition action in 2023, seeking division of the land and an accounting of income.The District Court of Grant County, South Central Judicial District, presided over a bench trial, during which the parties stipulated to the appointment of a referee to recommend partition options. Bryan advocated for an option that would award him sections including the family homeplace, but the court adopted a different recommendation (Recommendation 5), granting him the S1/2 of Section 33 and the NW1/4 of Section 34, and ordering the trust to pay him a sum based on the property’s value and his share of land income. The court later corrected a clerical mistake that had mistakenly awarded Bryan all of Section 33 instead of the S1/2, and denied Bryan's motions to alter or amend the judgment.On appeal, the Supreme Court of North Dakota reviewed whether the district court abused its discretion in adopting the referee’s recommendation, correcting clerical errors, and calculating Bryan’s share of income and expenses. The Supreme Court held that the district court did not abuse its discretion and that its findings were not clearly erroneous. However, the Supreme Court modified the judgment to require the trust to reimburse Bryan $2,417.20 for certain trust-exclusive expenses. The judgment was otherwise affirmed as modified. View "Tischmak v. Theurer" on Justia Law

Two siblings, Ryan and Nancy, disputed the administration of their father Hal’s estate and the status of his ownership interest in Tautphaus Park Storage, LLC (TPS), an Idaho storage facility business. Hal, who suffered from progressive dementia before his death, was TPS’s sole voting member and manager, with Nancy assisting in legal and management matters. Several amendments to TPS’s operating agreement changed ownership and management, culminating—after Hal’s death—in Nancy executing further amendments that retroactively transferred Hal’s economic interest to herself and changed accounting records. Nancy, an attorney, served as both Hal’s lawyer and later as personal representative of his estate. Ryan questioned whether Hal’s interest in TPS remained an estate asset and sought access to business records, which Nancy resisted.The siblings litigated issues in two related cases in Bonneville County: a probate case in the Magistrate Court regarding Hal’s estate, and a separate TEDRA (Trust and Estate Dispute Resolution Act) civil action in District Court initiated by Ryan. Both courts and parties at times treated the cases as consolidated. Ryan’s TEDRA complaint sought judicial determination of estate assets, breach of fiduciary duty, fraud, and appointment of a receiver, naming Nancy in both her individual and representative capacities and TPS as defendants. The magistrate court dismissed Ryan’s claims and removed Nancy and TPS as parties, finding that estate matters should be decided exclusively in probate. The district court affirmed, denying Ryan’s motions and dismissing his amended complaint, reasoning that Ryan’s claims were matters for probate only.On appeal, the Supreme Court of the State of Idaho vacated both lower courts’ judgments. It held that Ryan’s claims for judicial determination of estate assets and breach of fiduciary duty fall within TEDRA’s definition of “matters” and may be raised in a separate civil action, not only in probate. The Court reversed the orders dismissing claims and parties, remanded the case for further proceedings, and awarded costs and reasonable attorney fees to Ryan against Nancy personally. View "Monson v. Monson" on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law