Justia Civil Procedure Opinion Summaries

In 2015, Universitas Education, LLC initiated a lawsuit against Jack E. Robinson, III, alleging violations of the Racketeer Influenced and Corrupt Organizations Act. Robinson defended himself until his death in November 2017. After Robinson's death, the focus of the case shifted to finding a proper party to substitute as a representative of his estate. Universitas identified Lillian Granderson, Robinson's mother, as a suitable substitute and filed motions to substitute her into the case and to enter default judgment against her. The district court granted both motions.On appeal, Granderson argued that the district court erred in granting Universitas' motion to substitute and motion for default judgment. The United States Court of Appeals for the First Circuit affirmed the district court's decision to substitute Granderson into the case, but vacated the default judgment. The court found that Granderson had defended the case and no entry of default had been entered against her, which was a requirement for a default judgment. The case was remanded back to the district court for further proceedings consistent with the appellate court's opinion. View "Universitas Education, LLC v. Granderson" on Justia Law

The case involves a dispute over the will of Dennis Schmeling, who left his farmland to his sister-in-law, Sharon, in his 2021 will. Two of Dennis's brothers and one nephew contested the will, alleging undue influence by Sharon. The Estate moved for summary judgment, arguing that the contestants could not show that the devise was the result of undue influence, based on a previous court decision (In re Estate of Tank). The circuit court agreed with the Estate, concluding that there was no evidence showing that Dennis had a testamentary disposition toward the contestants and that the contestants did not present evidence showing that Sharon participated in the drafting of the disputed will or engaged in acts of undue influence. The contestants appealed this decision.The Supreme Court of the State of South Dakota reversed the circuit court's decision and remanded the case. The Supreme Court found that the circuit court had erred by granting summary judgment on grounds not raised by the parties and by granting the Estate's motion for summary judgment. The Supreme Court concluded that there were material issues of fact in dispute on the contestants' claim that the 2021 Will was the result of Sharon’s undue influence. Therefore, the circuit court erred in granting the Estate’s motion for summary judgment. The Supreme Court also found that the circuit court erred in denying the contestants' partial motion for summary judgment, as it was undisputed that neither the 2002 Will nor the 2021 Will contains language expressly disinheriting the contestants. View "In re Estate Of Schmeling" on Justia Law

The case at hand involves a dispute over the interpretation of a will left by Robert Pettengill Beckey, who was survived by his three children, Sandra L. Arthur, Angela M. Beckey, and Timothy E. Beckey. The will included specific instructions for dividing real property located at 848 Allen Pond Rd., Greene, ME, among the three children. However, the Maine Supreme Judicial Court found that the Probate Court erred in its interpretation of the will, particularly regarding Angela's share.Specifically, Angela's share was described in the will as "1/3 of property located at 848 Allen Pond Rd., minus the valuation of a piece of land on water by property line of 'Caron's'". The Probate Court had ruled that this description was ambiguous and that Angela's share therefore fell into the residue of the estate, to be divided equally among the three children. However, the Supreme Judicial Court found that the ambiguity of the "minus" clause was irrelevant because Robert never conveyed any part of the land to Angela. Therefore, Angela was entitled to a one-third share of the Allen Pond Road property’s value without any reduction.The Supreme Judicial Court concluded that the Probate Court's ruling was not consistent with Robert's intent for his children to receive equal shares of the property's value. The Supreme Judicial Court vacated the judgment and remanded the case for further proceedings consistent with its opinion. View "Estate of Robert Pettengill Beckey" on Justia Law

The Supreme Court of Appeals of West Virginia granted a writ of prohibition to defendant Denita D. Berg, preventing the Circuit Court of Grant County from enforcing orders to sell personal property before determining its ownership. The orders were part of a case brought by Denita Berg's stepchildren, who alleged that Berg had not properly inventoried their father's estate after his death and had committed fraud.The Supreme Court's decision was based on the fact that the orders to sell the property were issued despite the existence of genuine issues of material fact about who owned it. The Court explained that the circuit court's order was erroneous as a matter of law because it went beyond the requirements of Rule 56(c) of the West Virginia Rules of Civil Procedure. Rule 56(c) states that summary judgment should only be granted when there is no genuine issue as to any material fact and the party is entitled to the judgment as a matter of law.The Court concluded that the circuit court had exceeded its legitimate powers by ordering the sale of the property when ownership was still in dispute. Therefore, it granted a writ of prohibition, as moulded, to preclude the circuit court from ordering the sale of the disputed property. View "State of West Virginia ex rel. Berg v. Ryan" on Justia Law

In the case before the Maine Supreme Judicial Court, Christopher O’Donnell, as the personal representative of the estate of Erica J. O’Donnell, appealed a judgment from the York County Probate Court. The court had approved a referee's report regarding the distribution of the estate. O’Donnell contested several aspects of the report, including the application of the intestacy succession provisions of Title 18-A of the Maine Revised Statutes to Erica J. O’Donnell's estate and the court’s decision to adopt the referee's report without holding a hearing on O’Donnell's amended objection.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court concluded that the intestacy succession provisions of Title 18-A, not Title 18-C, applied because Erica J. O’Donnell died before the effective date of Title 18-C. The court also rejected O’Donnell's argument that he was deprived of a hearing on the referee’s report, finding that a hearing was held after the referee's report and O’Donnell's objections were received. The court ruled that O’Donnell's amended objection lacked the required level of specificity to preserve his objection to the plan of distribution. View "Estate of Erica J. O'Donnell" on Justia Law

The Supreme Court of the State of Montana was presiding over a dispute regarding the reimbursement claim of Angela Mastrovito from the Estate of Rebekah Barsotti. Mastrovito, the mother of the deceased Rebekah Barsotti, had served as her court-appointed guardian after Rebekah went missing and was presumed dead following a reported drowning accident. Mastrovito filed a claim for $140,688.45 in expenses she allegedly incurred during her guardianship, including costs for rent, legal fees, meals, travel, and others. The claim was opposed by Rebekah's husband, David Barsotti, who was appointed as the personal representative of Rebekah's estate.The District Court denied Mastrovito's claim for three reasons: her appointment as a guardian was retroactively improper due to Rebekah's death, the claimed expenditures were unreasonable, and the claim lacked sufficient substantiation. Mastrovito appealed this decision, arguing that her appointment was not improper and that she was denied a fair hearing to present evidence in support of her claim.Upon review, the Supreme Court affirmed the District Court's denial of the claim. The court reasoned that even if Mastrovito's appointment was proper, she still failed to provide sufficient support for her claim. The court concluded that a hearing could not change the fact that Mastrovito's claim was facially insufficient. The court underscored the need for providing supporting evidence to determine the validity and reasonableness of claimed costs. View "In re Estate of Barsotti" on Justia Law

The Supreme Court of Mississippi affirmed the trial court's decision to reform an irrevocable trust to reflect the original intent of the settlor. The settlor, Elton G. Beebe Sr., created a trust in 1992 with the aim of providing lifetime benefits to 16 named individuals. However, he claimed that a scrivener’s error in the trust document led to a misunderstanding about the distribution of the trust's assets upon the death of the last named beneficiary. The trust document stated that the assets would be distributed to the descendants of all 16 beneficiaries, but Beebe claimed that his intention was for the assets to be distributed to his own lineal descendants.The trial court found that the settlor provided clear and convincing evidence of his original intent and the mistake in the trust document. It reformed the termination provision of the trust to reflect the settlor's intent. The decision was appealed by several parties who were not in agreement with the reformation.The Supreme Court upheld the trial court's decision, finding that there was sufficient evidence to prove that the termination provision in the trust was a mistake of expression that did not reflect Beebe's intent at the time the trust was created. The court did not find any abuse of discretion in the trial court's finding. View "In the Matter of the Elton G. Beebe, Sr. Irrevocable Family Mortgage Trust v. Family Management, Inc." on Justia Law

In this case, GayLe Schleve, the personal representative of the estates of Viola J. Heath and Caleb C. Heath, appealed orders from the District Court of Dunn County, North Dakota, that granted Wells Fargo Bank's motions to vacate previous orders establishing the authority of domiciliary foreign personal representatives and letters testamentary related to the estate of Viola J. Heath, and determining heirs and successors in the estate of Caleb C. Heath.Viola and Caleb Heath were residents of Montana who owned mineral rights in Dunn County, North Dakota. After their deaths, litigation ensued over the distribution of these mineral rights. The orders being challenged in this appeal had resulted in the mineral rights being transferred to the heirs of Viola Heath.Wells Fargo, as successor to Norwest Capital Management & Trust Co., the trustee appointed in Caleb Heath's will, claimed an ownership interest in the mineral rights and challenged the transfer of those rights to the heirs of Viola Heath. Wells Fargo argued that the district court had lacked jurisdiction to issue the orders, and that the orders should be vacated because they were manifestly unjust and based on incorrect applications of the law.The Supreme Court of North Dakota held that Wells Fargo had standing to challenge the orders. The court also held that the district court had erred in ruling that it lacked subject matter jurisdiction to issue the order in the Estate of Viola J. Heath. However, the Supreme Court remanded for further determination of whether the district court had personal jurisdiction over the parties in the Estate of Viola J. Heath, and whether relief should be granted under Rule 60(b)(4) or Rule 60(b)(6).Finally, the Supreme Court held that the district court had abused its discretion in granting Wells Fargo's Rule 60(b)(6) motion to vacate the order in the Estate of Caleb C. Heath without sufficient findings related to timeliness. The Supreme Court therefore affirmed in part, reversed in part, and remanded the case for further proceedings. View "In re Estate of Heath" on Justia Law

In this case, the Supreme Court of Wyoming affirmed the lower court's decision to grant Mrs. Tokowitz the right to a spousal election against her late husband's will. The late Mr. Tokowitz had left his estate to a revocable trust and made no provision for Mrs. Tokowitz in his will. The court held that Mrs. Tokowitz was not deprived of her spousal election right simply because her husband's property was transferred to his trust through a pour-over will. The court reasoned that property transferred by a pour-over will is part of the decedent's probate estate until the will is probated. Only after probate does it pass in accordance with section 2-6-103 to the trust to be distributed by the trust terms. The court also found that Mr. Tokowitz was domiciled in Wyoming at the time of his death, as evidenced by his will, making Mrs. Tokowitz eligible for the spousal election under Wyoming law. The court declined to rule on Mrs. Tokowitz's rights as a beneficiary under the trust, stating that issues relating to the trust were outside of its jurisdiction. View "In the Matter of the Estate of Tokowitz v. Tokowi" on Justia Law

The Supreme Court of Rhode Island heard an appeal by Kelly Maltais contesting the dismissal of her probate appeal by the Superior Court. Kelly challenged the last will and testament of her father, Laurent E. Maltais, alleging fraud, duress, and undue influence, and asserting that her father lacked testamentary capacity. Kelly's probate appeal was dismissed by the Superior Court on the grounds that it was filed 32 days after the probate court order, two days beyond the statutory 30-day limit for appeal. Kelly argued that the 30th day fell on a Saturday, and under Rule 6 of the Superior Court Rules of Civil Procedure, she had until the following Monday to file her appeal.The Supreme Court of Rhode Island vacated the order of the Superior Court, ruling that the computation of time for the 30-day deadline is tolled when the last day for filing falls on a Saturday, Sunday, or a legal holiday, in order to give appellants the full benefit of all the time allowed, even if it necessitates giving an additional day. The case was remanded to the Superior Court for further proceedings consistent with this opinion. View "Maltais v. Maltais" on Justia Law