Justia Trusts & Estates Opinion Summaries

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

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.

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.