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 the Estate of Everett Joseph Hopkins in the Estate's action to declare a warranty deed null and void for failure of delivery, holding that the trial justice did not err or abuse her discretion.The trial justice determined that the warranty deed was void for failure of delivery because Everett did not intend to surrender control of and completely divest himself of title to the property. The trial justice further found that the deed was not accepted. The Supreme Court affirmed, holding that the trial justice properly determined that the executed warranty deed was void for failure of delivery and acceptance. View "Estate of Everett Joseph Hopkins v. Hopkins" on Justia Law

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The Supreme Court reversed the decision of the superior court granting summary judgment in favor of Appellee on the basis that Appellant failed to perfect her probate appeal under R.I. Gen. Laws 33-23-1, holding that Appellant perfected her probate appeal.Appellant, the surviving spouse of the decedent, filed a claim of appeal after the decedent's will, which named Appellee as executrix and left his law firm assets to her, was admitted to probate. The hearing justice granted summary judgment for Appellee, concluding that Appellant did not comply with the statutory requirements of section 33-23-1. The Supreme Court reversed and remanded the case, holding that there was competent evidence proving the existence of a disputed issue of material fact. View "Estate of John P. Garan" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant, as trustee of the Trust of Anna H. Blankstein, and dismissing Plaintiff's complaint for an accounting pursuant to R.I. Gen. Laws 18-13-15(b), holding that Plaintiff was not entitled to relief.Plaintiff, the beneficiary of the Trust of Anna H. Blankstein, brought this action requesting an accounting pursuant to the Rhode Island Uniform Custodial Trust Act (RIUCTA). Defendant moved for summary judgment, arguing that, by its terms, the trust was not a custodial trust, and therefore, Plaintiff was not entitled to an accounting of the trust. The trial justice granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding (1) Blankstein did not create a custodial trust because the trust did not meet the requirements set forth in RIUCTA; and (2) Plaintiff did not have standing as the administrator of the estate to request an accounting. View "Shorr v. Harris" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the judgment of the superior court granting summary judgment in favor of Plaintiff, the Estate of Michael F. Cassiere, on Plaintiff's claim for distribution of assets held in the Carmen D. Neumann Revocable Trust and on Defendant Joseph Cassiere's counterclaim for breach of fiduciary duty, holding that distribution of the trust was proper.Plaintiff brought this action seeking distribution of the trust's assets and termination of the trust. Defendant filed a counterclaim for breach of fiduciary duty. The trial justice granted summary judgment in favor of Plaintiff on both Plaintiff's claim and Defendant's counterclaim. The Supreme Court affirmed, holding (1) there was no evidence in the record to support the elements of a claim for breach of fiduciary duty; and (2) distribution of the trust was proper. View "Estate of Michael F. Cassiere v. Cassiere" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the superior court's grant of judgment as matter of law in favor of Defendant, individually and as trustee of The Gilbert F. Roy, Jr. Residence Trust - 2005, holding that the trial justice did not err.Plaintiffs sought a declaratory judgment that Defendant was holding property in a constructive trust for their benefit and asked the superior court to order Defendant to convey a co-tenancy interest to them. Plaintiffs requested monetary damages and asserted claims of promissory estoppel and unjust enrichment. The trial justice granted Defendant's motion for judgment as a matter of law. The Supreme Court affirmed, holding (1) the trial justice did not misapply the law of constructive trusts to the facts; (2) there was no error in the trial justice's finding that Plaintiffs failed to establish a valid promissory estoppel claim; and (3) the trial justice did not err in her analysis of Plaintiffs' unjust enrichment claim. View "Sousa v. Roy" on Justia Law

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