Justia Trusts & Estates Opinion Summaries

Articles Posted in Iowa Supreme Court

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In this intrafamily dispute regarding farmland the Supreme Court affirmed the rulings of the district court denying substitute petitioners' petition for relief from elder abuse specifically seeking relief for the loss associated with certain real estate transactions, holding that the substitute petitioners failed to prove that their father was a vulnerable elder at the time of the challenged transactions. The substitute petitioners for their father filed this petition pursuant to Iowa Code 235F alleging that their brother and his son committed elder abuse against their father by unduly influencing the father to enter into below-mark-rate lease agreements to farm the father's land, to gift some of the land to the brother and his son, and to write a new will to reflect the gifted land. The district court concluded that the substitute petitioners failed to establish that their father was a "vulnerable elder" subject to "financial exploitation" within the meaning of chapter 235F. The Supreme Court affirmed, holding that the substitute petitioners filed to prove by a preponderance of the evidence that their father was vulnerable elder at the time of the challenged transactions. View "Struve v. Struve" on Justia Law

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The Supreme Court vacated the decision of the court of appeals affirming the district court's denial of Defendant's motion for summary judgment, reversed the decision of the district court, and remanded to the district court for entry of summary judgment in favor of Defendants, holding that Plaintiffs' action was untimely. Plaintiffs, two beneficiaries of a trust, filed an action asking the district court to resolve a dispute with Defendant concerning the valuation date of the trust. Defendants moved for summary judgment on the grounds that Plaintiffs' action was untimely and the terms of the trust clearly provided the valuation date. The district court denied the motion. The court of appeals affirmed. The Supreme Court reversed the denial of summary judgment, holding that Plaintiffs failed timely to commence their action, and therefore, their claims were barred under Iowa Code 633A.4504. View "Konrardy v. Vincent Angerer Trust" on Justia Law

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The court of appeals erred in ruling that a taxpayer avoided in Iowa inheritance tax through a private postmortem family settlement agreement (FSA). Here, the decedent, before his death, signed a beneficiary form listing the taxpayer as a contingent beneficiary of his brokerage account. That account transferred to the taxpayer upon the decedent's death. The Iowa Department of Revenue (IDOR) determined that the estate owed the inheritance tax on the full account value. The decedent’s grandchildren sued the taxpayer claiming that they were entitled to the brokerage account under the decedent’s will because the decedent lacked the mental capacity to execute an enforceable beneficiary designation for the account. The taxpayer settled the suit by transferring half the account value to the plaintiffs under an FSA. The taxpayer then sought a refund of part of the inheritance tax already paid. The IDOR denied a refund, determining that the taxpayer failed to establish incapacity. The district court affirmed. The court of appeals reversed, concluding that the FSA controlled the tax issue. The Supreme Court vacated the decision of the court of appeals and affirmed the district court judgment, holding that, without an adjudication of incapacity, the FSA was not binding on the IDOR and could not avoid the inheritance tax. View "Nance v. Iowa Department of Revenue" on Justia Law

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In this will contest, the district court did not abuse its discretion in denying the unsuccessful will contestant’s motion to amend the pleadings to conform to the proof at the close of his case. The contestant’s motion at issue sought to broaden the contestant’s undue influence claim to include all of the testator’s prior wills and codicils. The Supreme Court held that the last-minute amendment would have broadened the issues and the proof. In addition, this issue fell within precedent upholding denials of motions to amend under Iowa R. Civ. P. 1.457 when the motion is based on facts the movant knew or should have known before trial. As to the contestant’s other issue asking the Supreme Court to overturn a ruling on burden of proof that was incorporated within a pretrial order denying summary judgment, this issue was not preserved for review. Accordingly, the Supreme Court vacated the decision of the court of appeals and affirmed the judgment of the district court. View "In re Estate of Margaret E. Workman" on Justia Law

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David Steinberg and Steven Steinberg, brothers and the sole beneficiaries of the Steinberg Family Living Trust, requested a declaration of how a Minnesota farm and an Iowa farm should be distributed. The Minnesota farm, which was part of the trust, was acquired after the creation of the trust through a like-kind tax exchange of property. The exchanged property was specifically bequeathed to Steven but the acquired farm was not specifically bequeathed to either beneficiary. The district court ordered the Minnesota farm to be distributed equally between the brothers, concluding that the specific bequest was adeemed because the bequeathed parcel of land was no longer an asset of the trust and there was no exception to the doctrine of ademption for the like-kind tax exchange of property. The court also struck a provision of the trust granting Steven the option to purchase the Iowa farm from David. The Supreme Court (1) affirmed the district court’s decision to the extent the court declared the specific bequest to Steven was adeemed and concluded that the Minnesota farm was to be distributed equally between the brothers; and (2) reversed the decision to the extent it granted summary judgment to David on the disputed trust provision due to genuine issues of material fact. View "Steinberg v. Steinberg" on Justia Law

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Joseph Gantner died in 2015, survived by his wife, Rachel Gantner, and two daughters, Meredith and Paige Gantner. After Joseph’s will was admitted to probate, Rachel filed for an elective share of Joseph’s estate and also requested a spousal support allowance. Meredith and Paige resisted Rachel’s application for spousal support, maintaining that several individual retirement accounts (IRAs) did not constitute part of the probate estate and, therefore, were beyond the reach of Rachel’s spousal allowance. As relevant to this appeal, Rachel was not a beneficiary of those IRAs. Rather, the executor confirmed that Meredith and Paige were their cobeneficaries. The probate court denied Rachel’s application for spousal allowance, concluding that the IRAs could not be used to pay an allowance to Rachel, who was not a beneficiary of those IRAs. Rachel appealed, arguing that she may reach the IRAs because they were “a transfer at death of a security registered in beneficiary form” under Iowa Code 633D.8. The Supreme Court affirmed, holding that chapter 633D does not apply to an IRA where one or more nonspouses are designated the beneficiaries. View "In re Estate of Joseph C. Gantner III" on Justia Law

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Testator executed a last will and testament devising property to her adult son and daughter. After the will was executed but before Testator’s death, Son was adopted by his paternal aunt. After Testator’s death, Daughter filed this action seeking a declaratory judgment establishing that the adoption terminated Son’s ability to inherit under Mother’s will, which identified him as a beneficiary both by name and by membership in a class. The district court concluded that Son’s adoption out of his biological family did not preclude him from taking under Mother’s will. The Supreme Court affirmed, holding that the testamentary gift to Son as a named beneficiary and as a member of a class did not fail because of his adoption as an adult after Testator executed her will. View "Roll v. Newhall" on Justia Law

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Arnold and Vesta Melby were trustors of separate irrevocable trusts. Both Arnold and Vesta received Medicaid benefits. After the Melbys’ deaths, the Iowa Department of Human Services notified Arnold’s estate that it would seek reimbursement for all Medicaid expenses it had paid on behalf of Arnold and Vesta. The Department then filed an application in the estate seeking a judgment declaring the Melbys had interests in the corpus of their trusts that should be counted as assets available for repayment of the Department’s Medicaid claim. The district court concluded (1) the Melbys’ interests in the trusts were limited to their right to receive the net income from the trusts’ assets, and (2) the Department’s right to recover the Medicaid payments could be enforced against such income, but not against the corpus of the trusts. The Supreme Court reversed, holding (1) the Department’s right to recover Medicaid payments under the facts of this case extended beyond the Melbys’ net income interests; and (2) the district court erred in determining the scope of medical assistance for which recovery was authorized by the general assembly. Remanded. View "In re Estate of Melby" on Justia Law

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Defendant, a financial advisor to Decedent, was sued by identified beneficiaries of Decedent’s signed written estate plan. The beneficiaries alleged that Defendant was negligent in the performance of his duties, and therefore, the beneficiaries did not receive what they were supposed to receive under the plan. The district court granted summary judgment in favor of Defendant, concluding that Defendant, a non-attorney, owed no duty to the beneficiaries. The Supreme Court (1) reversed the judgment entered against plaintiff Steve Bristol and his spouse, holding that Bristol was owed a duty by Defendant and that Bristol raised a genuine of material fact as to whether Defendant’s negligent performance of his agency responsibilities caused Bristol not to receive a specific devise set forth in Decedent’s will; and (2) affirmed the judgment with respect to the charitable recipient plaintiffs, as their damages were too speculative to establish damages. View "St. Malachy Roman Catholic Congregation of Geneseo, Ill. v. Ingram" on Justia Law

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The parties in this case, William and Steven Burkhalter, were the sons of Louis Burkhalter. William challenged an unfavorable modification of Louis's revocable trust that occurred just before Louis's death, claiming (1) Steven unduly influenced Louis and tortiously interfered with the trust, and (2) Louis lacked the necessary testamentary intent when he made the modification. The district court directed a verdict for Steven on the tortious interference claim, and the jury returned a verdict for Steven on the testamentary capacity and undue influence claims. The court of appeals remanded the case for a new trial on the undue influence claim, concluding that the district court erroneously instructed the jury on undue influence, and the error prejudiced William. The Supreme Court vacated the decision of the court of appeals and reinstated the jury verdict on the undue influence claim, holding that the district court's instruction accurately reflected the law of undue influence and did not unduly emphasize the causation element of the undue influence claim. View "Burkhalter v. Burkhalter" on Justia Law