Justia Rhode Island Supreme Court Opinion Summaries

Articles Posted in Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court in favor of South County Hospital, Home & Hospice Care of Rhode Island and Emmy Mahoney, M.D. (collectively, Defendants), and dismissing all claims alleged by Plaintiff individually and on behalf of the Guardianship of Joyce C. Willner, holding that the trial justice did not err in dismissing the claims. Plaintiff filed an eight-count complaint against Defendants, individually and as guardian of Joyce Willner, his mother. The trial judge granted Defendants' motions to dismiss and motions for summary judgment, dismissing all claims. The Supreme Court affirmed, holding that the trial justice did not err in (1) dismissing the claims alleged by Plaintiff on behalf of the guardianship because Joyce had no right to be represented by Plaintiff, who was not authorized to practice law; and (2) denying Plaintiff's request to appoint a guardian ad litem. View "Willner v. South County Hospital" on Justia Law

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The Supreme Court affirmed the judgment of the superior court affirming rulings of the probate court and holding that the father (the decedent)Plaintiffs and Defendant had validly executed a last will and testament on June 9, 2011, holding that the last will and testament executed by the decedent on June 9, 2011 was valid. Plaintiffs alleged that the last will and testament was invalid because, on June 9, 2011, the decedent continued to be subject to a temporary limited guardianship, which included a provision prohibiting the Decedent from revoking or drafting any last will and testament. The superior court justice concluded that because the probate court had, on December 13, 2010, dissolved all portions of the guardianship restricting the decedent's ability to make a will, the last will and testament at issue was not invalid. The Supreme Court affirmed, holding that because the condition limiting the decedent's ability to revoke or draft a last will and testament was extinguished by the probate court in 2010, the last will and testament executed by the decedent in 2011 was valid. View "Duffy v. Scire" on Justia Law

Posted in: Trusts & Estates
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In this dispute among siblings regarding amendments to an inter vivos trust and gifts of interest in a family limited partnership established by Augusta Hathaway the Supreme Court affirmed the judgment of the superior court and vacated the grant of a new trial as to Plaintiff's breach of fiduciary duty claim, holding that the order granting a new trial was unnecessary. A jury found that Hathaway lacked the testamentary capacity to amend her trust and that Defendant Marion Louttit, Hathaway's daughter, had unduly influenced Hathaway, thereby causing Hathaway to execute challenged amendments and gifts. The jury further found that Louttit breached her fiduciary duty as trustee. After the jury's verdict, the trial justice granted Louttit's motion for new trial and judgment as a matter of law as to the fiduciary duty verdict because Plaintiff Wenda Branson, Hathaway's daughter, had failed to prove damages. The Supreme Court affirmed the judgment in all respects, holding (1) Branson's claims were not barred by the equitable doctrine of laches; (2) Louttit's motions for judgment as a matter of law and for new trial on the issue of undue influence was properly denied; and (3) the grant of a new trial on the issue of fiduciary duty is vacated as superfluous. View "Branson v. Louttit" on Justia Law

Posted in: Trusts & Estates
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In this dispute surrounding the distribution of the assets of the parties' deceased mother the Supreme Court affirmed the judgments of the superior court with respect to the substance of two orders of the probate court, holding that two bank accounts should be distributed pursuant to paragraph three of the decedent's will and that there was no basis to remove the current executrix of the decedent's estate. The decedent's children were Michaela, Mark, Lizbeth, and Lisa. Lizbeth was named executrix of the decedent's estate. The probate court determined that the two accounts at issue were part of the "general inventory" of the estate and, therefore, the proceeds of those accounts should be distributed under paragraph six of Catherine's will - i.e., divided equally among all four of Catherine's children. Lizbeth appealed. When Michaela and Mark unsuccessfully sought to remove Lizabeth as executrix, they appealed. The two appeals were consolidated. The superior court concluded that the accounts were not estate assets and, pursuant to paragraph three of the decedent's will, should be distributed to Lisa and Lizbeth respectively. The court affirmed the probate court's decision not to remove Lizabeth as executrix. The Supreme Court affirmed both judgments of the superior court, holding that the trial justice did not err in its judgment. View "Larkin v. Arthurs" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court dismissing Appellant's probate appeal after finding that, because Appellant was under guardianship, he lacked the capacity to retain legal counsel and file an appeal to the superior court in his own name, holding that the superior court properly dismissed Appellant's appeal on the ground that Appellant lacked the capacity to bring and maintain an action in his own name. On appeal, Appellant argued that the superior court erred in dismissing his probate appeal because he was only under a limited guardianship and was thus entitled to pursue the probate appeal on his own. The Supreme Court affirmed, holding that Appellant was not under a limited guardianship, but, rather, a full guardianship, and did not retain the right to pursue this action on his own behalf. View "In re Estate of Amet Chelo" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court remanded with directions to modify the superior court's April 22, 2013 attorneys' fees order, affirmed in part and vacated in part the April 26, 2013 judgment of the superior court, and affirmed the court's June 5, 2013 order, holding that the sanctions order was overly broad and the amount of attorneys' fees was excessive. This case began with a dispute over Appellant's aunt's estate after she died. The April 22, 2013 order awarded attorneys' fees to opposing counsel. The April 26, 2013 judgment denied and dismissed Appellant's probate appeal and prohibited Appellant from filing pleadings or other documents in the superior court unless signed by a licensed attorney. The June 5, 2013 order denied Appellant's motions to vacate that were filed pursuant to either Rule 59 or Rule 60 of the Superior Court Rules of Civil Procedure. The Supreme Court held (1) the sanctions order was overly broad in duration, infringing on Appellant's right of access to the courts; (2) a twenty-five percent reduction in the amount of attorneys' fees to be awarded was appropriate; and (3) Appellant's contentions on appeal with respect to her motions to vacate were unavailing. View "In re Estate of Elizabeth Brown" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court dismissing Plaintiff’s probate court appeals for his failure to comply with several court orders, holding that the superior court justice properly exercised his discretion in dismissing Plaintiff’s appeals. Ostensibly acting as successor executor for the wills of two former clients, Appellant challenged probate court orders relating to guardianship decrees. The superior court dismissed Appellant’s five probate court appeals for Appellant’s failure to comply with the court’s orders. The Supreme Court affirmed, holding (1) the superior court justice did not abuse his discretion; and (2) because Appellant’s representations to the probate courts, the superior court, and the Supreme Court were not as forthcoming as the rules of procedure require, the case is remanded to allow Defendants an opportunity to file a motion for sanctions if they so choose. View "Malinou v. Neri" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court granting Plaintiff’s request for declaratory relief and prohibiting Defendant from transferring assets of the decedent’s irrevocable living trust into the decedent’s estate. Plaintiff and Defendant were the two surviving children of the decedent. After Defendant was appointed as the personal representative of the decedent’s estate, Plaintiff filed a complaint seeking to prevent Defendant from transferring the assets of the irrevocable trust into the decedent’s estate. Specifically, Plaintiff alleged that Defendant intended to transfer assets from the irrevocable trust to the decedent’s estate by exercising the limited power of appointment in a provision of the irrevocable trust. The district court issued a decision in favor of Plaintiff. The Supreme Court affirmed, holding that Defendant’s intended exercise of the limited power of appointment contained in the decedent’s irrevocable living trust was invalid. View "Jaffe v. Pournaras" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court granting Plaintiff’s request for declaratory relief and prohibiting Defendant from transferring assets of the decedent’s irrevocable living trust into the decedent’s estate. Plaintiff and Defendant were the two surviving children of the decedent. After Defendant was appointed as the personal representative of the decedent’s estate, Plaintiff filed a complaint seeking to prevent Defendant from transferring the assets of the irrevocable trust into the decedent’s estate. Specifically, Plaintiff alleged that Defendant intended to transfer assets from the irrevocable trust to the decedent’s estate by exercising the limited power of appointment in a provision of the irrevocable trust. The district court issued a decision in favor of Plaintiff. The Supreme Court affirmed, holding that Defendant’s intended exercise of the limited power of appointment contained in the decedent’s irrevocable living trust was invalid. View "Jaffe v. Pournaras" on Justia Law

Posted in: Trusts & Estates
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Plaintiff, the grandnephew of the decedent, filed this action against Defendant, the decedent’s sister and the beneficiary of an Amica Insurance Company annuity policy created by the decedent. The complaint alleged forgery, fraud, manipulation, false pretenses, and misrepresentation. The trial court entered judgment in favor of Defendant. The Supreme Court affirmed, holding (1) the trial justice did not misapply the law to the evidence; (2) the trial justice did not overlook or misconceive material evidence pertaining to the beneficiary-change forms; (3) the trial justice did not err in failing to take judicial notice of the findings made by another superior court justice after a hearing on Plaintiff’s request for a preliminary injunction; (4) the was no error on the part of the superior court in refusing to shift the burden of proof to prove absence of mistake; and (5) the trial justice did not err in finding that Defendant was forthright and credible. View "Quillen v. Macera" on Justia Law

Posted in: Trusts & Estates