Justia Trusts & Estates Opinion SummariesArticles Posted in Minnesota Supreme Court
Miller v. Molloy
The Supreme Court affirmed as modified as modified the decision of the court of appeals reversing the judgment of the district court denying Maria Molloy's motion to intervene in Pamela Spera's proceeding seeking enforcement of a divorce decree that dissolved her marriage to Rodney Miller, holding that Molloy had a right to intervene as to the valuation of Miller's retirement accounts.In the enforcement proceeding, Spera sought to have the retirement accounts she and Miller each held divided according to the terms of the divorce decree. Before Miller passed away, he named his four daughters - including K.M.M., the child he had with Molloy - as beneficiaries on his retirement accounts. Molloy sought to intervene in Spera's enforcement proceeding as a matter of right to assert K.M.M.'s interest in Miller's retirement accounts. The district court denied intervention. The court of appeals reversed, concluding that the four requirements under Minn. R. Civ. P. 24.01 for intervention were met. The Supreme Court affirmed as modified, holding that Molloy's right to intervene was limited specifically to the valuation of Miller's retirement accounts. View "Miller v. Molloy" on Justia Law
Hansen v. U.S. Bank National Ass’n
The Supreme Court reversed the decision of the court of appeals affirming the district court's dismissal of Appellants' complaint against U.S. Bank on statute of limitations grounds, holding that Appellants' breach of fiduciary duty claim was timely.On January 24, 2017, Appellants filed their lawsuit, alleging breach of fiduciary duty and unjust enrichment. U.S. Bank moved to dismiss the claim, arguing that Appellants failed to satisfy the applicable six-year statute of limitations. In response, Appellants asserted that they had suffered no damages earlier than August 2012. The district court granted the motion to dismiss, concluding that Appellants could have raised their claims in April 2010. The court of appeals affirmed, concluding that "some damage" occurred on April 27, 2010. The Supreme Court reversed, holding that U.S. Bank failed to establish - based on the pleadings - that Appellants suffered "some damage" in the form of financial harm before August 2012, and therefore, the district court erred by granting the motion to dismiss. View "Hansen v. U.S. Bank National Ass'n" on Justia Law
Laymon v. Minnesota Premier Properties, LLC
The Supreme Court affirmed the decision of the court of appeals interpreting Minn. Rev. Stat. 524.3-101 to allow real property to devolve immediately upon a testator’s death to a residual devisee.Plaintiff, in her capacity as personal representative to her father’s estate, sued Defendants to quiet title to residential property owned by her father at his death. Plaintiff’s brother, John, conveyed his interest in the property by quitclaim deed to Minnesota Premier Properties a few days after Wells Fargo bought the foreclosed property at a sheriff’s sale after the decedent’s death. The district court granted summary judgment to Plaintiff, concluding that John did not have an interest to convey to Premier through the quitclaim deed. The court of appeals reversed, holding that, under section 524.3-10, a valid, transferable ownership interest in real property devolves immediately upon a testator’s death to a person to whom the property is devised by the testator’s will. The Supreme Court affirmed, holding that the court of appeals did not err in interpreting the statute. View "Laymon v. Minnesota Premier Properties, LLC" on Justia Law
Bradison vs. Comm’r of Revenue
In 1995, Katelyn Janson was severely injured in an automobile accident. A lawsuit ended with a settlement in which two annuities were established, both of which guaranteed payments to Katelyn starting in 2001 and established that, if Katelyn died before fifteen years expired, annuity payments would be made to her estate. Katelyn's mother and conservator, Candy Bradison, moved Katelyn to Wyoming in 2001 and to Minnesota in 2003. In 2006, Katelyn died. In 2010, Bradison sought, on behalf of Katelyn's estate, a refund of the amount the estate previously paid to the Minnesota Department of Revenue, arguing (1) the annuity payments were not includable in Katelyn's estate because Katelyn did not own the annuities; and (2) Katelyn was a Wyoming domiciliary at the time of her death. The tax court concluded (1) Katelyn was a Minnesota domiciliary at the time of her death; and (2) the annuity payments were includable in Katelyn's estate. The Supreme Court affirmed, holding (1) Katelyn's intangible property had a situs in Minnesota at the time of her death and could be taxed in accordance with Minnesota's estate tax provisions; and (2) Katelyn was the beneficial owner of the annuity payments, and the value of the payments was properly included in her estate. View "Bradison vs. Comm'r of Revenue" on Justia Law
In re Pamela Andreas Stisser Grantor Trust
Vernon Stisser, the personal representative of the estate of Pamela Stisser, petitioned the district court for an order directing certain payments and disbursements from Pamela's inter vivos trust (Trust). Among other claims, Vernon sought an order requiring trustee David Andreas (Trustee) to (1) pay all debts at the time of Pamela's death that were secured by Pamela's personal property and by Pamela's and Vernon's real estate; (2) compensate Vernon for his services as the personal representative of Pamela's probate estate; and (3) reimburse Pamela's estate for all probate estate administration expenses. The court granted Trustee's motion for partial summary judgment on Vernon's claim for payment of the secured debts. After a trial on Vernon's remaining claims, the court concluded the Trust did not require Trustee to compensate Vernon for his services as personal representative and required Trustee to pay only a limited amount of Vernon's claim administration expenses. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding that the court of appeals incorrectly held that Trustee was required to pay debts secured by Pamela's personal property. View "In re Pamela Andreas Stisser Grantor Trust" on Justia Law
Fannie Mae v. Heather Apartments Ltd. P’ship
The property at issue in this case was the interest of Respondent, the judgment debtor, in a spendthrift trust. The district court issued a temporary injunction prohibiting Respondent from disposing of any money or property he had received, was due to receive, or will receive from the trust. The court of appeals reversed. The Supreme Court affirmed, holding (1) based on its plain language, Minn. Stat. 575.05 authorizes a district court to enjoin the deposition of a judgment debtor's property only if that property is in the hands of the judgment debtor or a third party or is due to the judgment debtor at the time the district court issues its order; and (2) because the judgment creditor, Appellant Fannie Mae, did not argue that Respondent's interest in the trust was Grossman's property that was currently in the hands of Grossman or a third party or currently due to Grossman, the requirements of section 575.05 were not met. View "Fannie Mae v. Heather Apartments Ltd. P'ship" on Justia Law
In re Estate of Butler
Before his death, Patrick Butler designated Appellant Maureen Kissack, one of his natural daughters, as joint owner of five certificates of deposit (CDs) with the right of survivorship. After Butler's death, the district court appointed Kissack as the personal representative of Butler's estate. Kissack, believing the CDs were nonprobate assets that she now owned, redeemed several of them and withdrew the proceeds without including the CDs in the inventory of estate assets filed with the district court. After another one of Butler's children protested this action, the district court ruled that the CDs were assets of Butler's estate and were subject to probate. After granting Kissack's motion for a new trial, the district court ruled in favor of Respondents, Butler's other natural daughters and surviving stepchildren. At issue on appeal was whether Respondents presented sufficient evidence to overcome the statutory presumption in favor of survivorship rights for joint accounts. The Supreme Court reversed the district court, holding that because Minn. Stat. 524.6-204(a) requires that the evidence offered to overcome the statutory presumption must specifically refer to the joint accounts at issue, Respondents failed to present sufficient evidence to satisfy their burden of proof. Remanded.
U. S. Bank N. A. v. Cold Spring Granite Co.
Appellants were trustees of eight family trusts. After stock of closely-held corporation belonging to the trusts was fractionalized in a reverse stock split and Appellants were forced to accept cash in exchange for their shares, Appellants brought suit against the corporation. The district court dismissed all of Appellants' claims. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the valuation of the stock was not the product of common law fraud; (2) Minn. Stat. 302A.471 does not provide for dissenters' rights in the event of a reverse stock split; (3) Appellants were not entitled to equitable relief under Minn. Stat. 302A.751 because the corporation did not frustrate Appellants' reasonable expectations as shareholders; (4) merely conducting an involuntary redemption of Appellants' stock at a fair price, without more, did not constitute a breach of fiduciary duty; and (5) the district court did not err in determining the fair value of Appellants' stock when it adopted a valuation that relied in part on asset value.