Justia Trusts & Estates Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus directing the circuit court to dismiss the underlying circuit court action filed by three sisters (Sisters), holding that the circuit court correctly denied the writ.The Sisters, daughters of Elbert Goff Sr., brought the underlying complaint against, among others, Appellant, individually and in her capacity as the personal representative of Elbert's Estate, alleging that Appellant breached her fiduciary duties to Elbert before he died through self-dealing. The circuit court denied Appellant's ensuing motion to dismiss. Appellant petitioned the court of appeals for a writ of mandamus directing the circuit court to dismiss the Sisters' complaint, but the court of appeals denied the request. The Supreme Court affirmed, holding (1) the circuit court had subject-matter jurisdiction in this case; and (2) an appellate remedy was available, and great injustice and irreparable injury will not be suffered by Appellant. View "Goff v. Honorable Edwards" on Justia Law

The Supreme Court reversed the decision of the court of appeals for failing as a reviewing court to give proper deference to the trial court's decision to deny Appellees leave to amend a pleading and held that the court erred when it found that the district court lacked jurisdiction to probate the will at issue in this action.Plaintiff filed this action challenging the validity of the decedent's will and asserting claims of undue influence and breach of fiduciary duty by Defendants and requesting a declaration that the will was invalid. After Plaintiff settled his claims with some of the defendants, defendant Suzanne McGaha filed a motion for leave to amend her answer and to assert cross-claims and certain objections. The district court overruled the motion. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that the district court lacked jurisdiction over the probate matter because of an alleged defect with verification of the probate petition; and (2) the circuit court did not abuse its discretion by denying Suzanne's motion for leave to amend her answer to assert cross-claims. View "McGaha v. McGaha" on Justia Law

The Court of Chancery held that the petition in this case alleging that Respondent, a former teacher, befriended and manipulated a woman, now deceased, through coercion into receiving millions of dollars of the woman's inheritances should be dismissed in full, with prejudice.Petitioner filed a verified petition to, among other things, invalidate will and trust agreements, for breach of a fiduciary duty, and demand for accounting. Respondent filed a motion to dismiss. The Court of Chancery granted the motion, holding (1) most of Petitioner's claims were either expressly time barred or sought a collateral attack on the incontestable final wishes of the decedent and that there was no viable basis for tolling the applicable limitations; and (2) Petitioner did not have standing to assert her remaining claims. View "Rambo v. Fischer" on Justia Law

In this dispute among four siblings over the ownership of 200 acres of farmland the Supreme Court reversed the judgment of the court of appeals reversing the order of the district court that the farmland be distributed to Neal Johnson and Thomas Johnson, holding that the court of appeals failed to apply well-settled common law.This dispute stemmed from the last will and testament of the aunt of the four siblings in this case - Neal, Thomas, Sylvia Perron, and Lee Johnson. The aunt, Hazel Bach, devised the farmland to Neal and Thomas based on certain conditions that were resolved in an agreement between the parties. Although Lee, acting as co-personal representative, refused to honor the agreement, the district court ordered that the farmland be distributed to Neal and Thomas. The court of appeals reversed. The Supreme Court reversed, holding that Neal and Thomas were entitled to the 200 acres under Bach's will. View "In re Estate of Bach" on Justia Law

Alexis Carroll Hartline and Zachary Shawn Hartline sought an interim allowance for their maintenance during the administration of the succession of Raymond John Brandt (“Decedent”). It was undisputed that the Hartlines were Decedent’s forced heirs by adoption (hereinafter, the “Forced Heirs”) and that Decedent entered into a last will and testament placing their legitime in trust. It was further undisputed that Decedent designated the Forced Heirs as principal beneficiaries of the relevant trusts and designated his surviving spouse, Jessica Fussell Brandt (the “Surviving Spouse”), as income beneficiary, thus granting her the sole right to any and all net income generated by the estate property held in trust for the duration of her life. The Louisiana Supreme Court granted the Forced Heirs’ writ to review whether they were entitled to receive the requested allowance as an advance on amounts they were “eventually due,” pursuant to La. C.C.P. art. 3321. The Supreme Court found the Forced Heirs could not receive an interim allowance during the administration of Decedent’s succession because they were not due, upon the termination of the administration, cash and/or property from which cash might be made available. The Court thus affirmed the court of appeal and remanded the matter to the district court for further proceedings. View "Succession of Raymond John Brandt" on Justia Law

In October 1998, Andrea and Brad Hall, together with Linda and Frank Exler, purchased real property in Roberts, Idaho. The Halls owned a two-thirds interest in the property and the Exlers owned one-third. In September 2005, Linda deeded all of her interest in the property to Frank. Frank died intestate in March 2006. Travis Exler, Frank’s son and sole heir, was appointed as the personal representative of Frank’s estate (“the Estate”). The parties dispute their relationship in the years between Frank's death and the filing of the underlying lawsuit. Brad testified he received notice from the County rearding unpaid taxes on the property. Travis said he was unable to pay the Estate's portion of the overdue taxes. Brad testified the parties reached an agreement by which Travis would deed the property to the Halls if they paid the outstanding tax balance. Within weeks of their conversation, Brad contacted a law firm to prepare a quitclaim deed. In contrast, Travis stated he would transfer the Estate’s interest in the property if the Halls reimbursed his costs associated with cleaning up the property. Travis testified that in 2009 the parties also agreed the Halls would take care of cleanup costs and taxes. Travis stated that he did not transfer ownership of the property to the Halls and was never presented with a quitclaim or personal representative’s deed. It was undisputed that the Halls had sole control, use, and operation of the property since 2009. The Halls oversaw the administration of the lease and maintenance of the property. Travis did not list any profit or loss from the property on his personal taxes. In addition, the Halls paid the overdue taxes on the property, and made all tax payments on the property since 2009. The Halls and Travis did not communicate between 2009 and 2019. In June 2010, Travis voluntarily filed for Chapter 13 bankruptcy. Travis did not list the property on his bankruptcy petition. The Chapter 13 Bankruptcy Trustee moved to dismiss based on Travis’s failure to list an interest in the property, rental income, and the transfer of an apartment building and 150 cattle. The bankruptcy court dismissed Travis’s petition. After Travis refused the Halls’ request to reopen probate of the Estate, the Halls filed a complaint to quiet title to the property. The district court issued a memorandum decision and order, quieting title to the disputed property in the Halls based on the lost deed doctrine. Travis appealed, but finding no reversible error, the Idaho Supreme Court affirmed the district court's order. View "Hall v. Exler" on Justia Law

The Supreme Court affirmed the judgment of the county court denying Nebraska Synod (Synod) of the Evangelical Lutheran Church in America's complaint in intervention after a county court determined that the Synod was not Pella Evangelical Lutheran Church's charitable successor and assign, holding that the Synod did not prove it was a charitable successor of Pella.Before her death, Margaret L. Matthews established and amended a revocable trust wherein she made three bequests - one each to the Salvation Army and the Visting Nurse Association (VNA) and one to Pella. Each bequest encompassed the named beneficiary, as well as its charitable successors and assigns. Wells Fargo Bank, N.C., as trustee, filed a petition for declaratory judgment concerning Pella's existence. The county court ordered that Pella's share of the trust property be distributed pro rata to the Salvation Army and the VNA after concluding that Pella had ceased to exist and that Synod was not an appropriate successor to Pella. The Supreme Court affirmed, holding that the Synod's assigned errors were without merit. View "In re Margaret L. Matthews Revocable Trust" on Justia Law

The Supreme Court affirmed the order of the court of appeals dismissing Appellant's appeal from the district court's denial of his petition to create a constructive trust, holding that the court of appeals did not err by dismissing the appeal for lack of appellate jurisdiction.Joseph Figliuzzi, who created a trust for holding wetland credits, sought to hold the credits in his own name rather than in the trust. After Figliuzzi died, Appellant brought this action seeking to confirm that the trust owned the subject credits and to establish a constructive trust over the disputed credits. The district court denied relief, concluding that Figliuzzi owned the credits at the time of his death. The court of appeals dismissed Appellant's ensuing appeal for lack of jurisdiction. The Supreme Court affirmed, holding (1) because the order being appealed from lacked finality, it could not be appealed under Minn. R. Civ. App. P. 103.03(g); and (2) the district court's order was not a denial of injunctive relief. View "In re Estate of Joseph Rocco Figliuzzi" on Justia Law

Gwendolyn Barnett and Robert Lee Hull, Jr. were siblings and the sole legal heirs of their father, Robert Lee Hull, Sr. ("Robert"), who died testate. Pursuant to Robert's will, Hull and Barnett were listed as beneficiaries entitled to equal shares of his estate and Barnett was named personal representative of his estate. In August 2019, Barnett obtained letters testamentary from the Probate Court. The administration of Robert's estate ("the estate administration") was later removed to the Circuit Court and assigned case no. CV-19-900322 following Hull's filing of a verified petition for removal. While the estate administration continued, Hull commenced the underlying action, a separate civil action against Barnett in the Circuit Court ("the tort action"), which was assigned case no. CV-20- 900192. Hull's complaint in the tort action alleged that Barnett, in her role as "a partial caretaker of [Robert]" before his death, had exerted undue influence over Robert and had gained control of Robert's personal property and assets. According to Hull, in the absence of Barnett's purported misconduct, items that Barnett allegedly misappropriated would "have become part of [Robert's] estate." Among other relief, Hull sought the imposition of a constructive trust "in an effort to avoid [Barnett's] further unjust enrichment." Barnett filed a motion seeking to dismiss the tort action. In her motion, Barnett asserted that Hull's complaint in the tort action realleged claims purportedly "identical" to claims that Hull had previously asserted in the estate administration, which had been dismissed. The trial court in the tort action entered an order granting Hull's motion in full. Barrett appealed, arguing the trial court lacked jurisdiction over Hull's claims. The Alabama Supreme Court concurred the trial court lacked jurisdiction over matters relating to the pending estate administration. It reversed all orders entered by the trial court in the tort action, and remanded for that court to enter an order dismissing Hull's complaint. View "Barnett v. Hull" on Justia Law

Jones established a trust, naming his daughter (Spencer) as successor trustee. The property was the trust’s principal asset. Jones later married Grays-Jones, but did not amend the trust. Jones contracted to sell the property to CDI for $13.6 million. Jones died shortly thereafter. Months later, Grays-Jones petitioned for an interest in Jones’s estate as an omitted spouse. While the property was still in escrow, Grays-Jones and Spencer, as trustee, agreed the trust “shall pay to [Grays-Jones] a total of $3,000,000 . . . as her full and final settlement of [Grays-Jones’s] interest in the Estate. Payment of said amount shall be paid ... out of the escrow from the sale of the [property].” Grays-Jones would move out of Jones’s residence in exchange for $150,000, which would constitute “an advance against the total settlement.” A stipulated judgment incorporated the settlement. Spencer, as trustee, paid Grays-Jones $150,000; Grays-Jones moved out of Jones’s residence. The sale of the property fell through. Spencer did not pay Grays-Jones the outstanding $2.85 million.Grays-Jones sought to enforce the stipulated judgment, alleging Spencer frustrated the sale of the property. She requested the appointment of a temporary trustee to sell the residence and property. The trial court denied the petition, finding the settlement agreement unenforceable because the sale was a condition precedent. The court of appeal reversed. The settlement agreement contained a condition precedent as to the method of payment, but Spencer’s independent promise to pay $3 million is enforceable and remains payable upon the property’s sale. View "Estate of Jones" on Justia Law