Justia Trusts & Estates Opinion Summaries

Articles Posted in Iowa Supreme Court
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The Supreme Court reversed the judgment in favor of Plaintiff in this will contest, holding that a claim alleging that the decedent's will resulted from tortious interference by a beneficiary must be joined with a timely will contest and otherwise is barred. Mother and Father died within one day of each other, and their 2014 mirror wills were probated. Plaintiff decided to forgo a timely contest to Mother's will but then later brought a suit for tortious interference against a Beneficiary of the will, arguing that the Beneficiary exercised improper and undue influence over Mother. The jury returned a verdict in favor of Plaintiff. The Supreme Court reversed, holding (1) the common law and principles of claim preclusion do not permit a tortious interference with inheritance claim alleging an improperly obtained will to go forward outside normal probate deadlines and proceedings; and (2) Plaintiff's tortious interference claim was a de facto substitute for a will contest based on undue influence and was thus barred because it was not brought in conjunction with a timely will contest. View "Youngblut v. Youngblut" on Justia Law

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The Supreme Court reversed the judgment of the district court ruling that Plaintiffs' claim seeking contract damages was barred by the limitations period set forth in Iowa Code 614.17A, holding that the district court erred in granting summary judgment. John and Dessie Rottinghaus filed a claim in the Estate of Sandra Franken, alleging that the Estate sold certain real estate in violation of their right of first refusal to purchase the real estate. The executor disallowed the claim and moved for summary judgment, claiming that section 614.17A barred the Rottinghauses' claim. The district court granted the motion for summary judgment, concluding that the statute of limitations precluded the Rottinghauses' claim for damages. The Supreme Court reversed, holding (1) section 614.17A applies only to actions seeking to recover or establish an interest in or claim to real estate filed against the holder of the record title; and (2) neither the merger doctrine, the statute of frauds, the indirect effect of section 614.17A, nor the statute of limitations in section 614.1(5) barred the Rottinghauses' damages action. View "In re Estate of Franken" on Justia Law

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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