A party filing a petition in probate to enforce a no contest clause triggers the anti-SLAPP statute

David Tate, Esq., Royse Law Firm, California (Silicon Valley/Menlo Park Office, with additional offices in San Francisco, Los Angeles and Orange County), http://rroyselaw.com/

The following is a brief discussion about a new California case in which the court held that a party filing a petition in probate to enforce a no contest clause triggers the anti-SLAPP statute. If you have never been involved in the anti-SLAPP statute, it is a big deal. The case is Urick v. Urick, California Court of Appeal, Second Appellate District, Case No. B278257 (October 5, 2017).

Summary. Filing a petition for instructions in probate, claiming that a trustee or beneficiary had triggered a no contest clause by filing her prior petition to reform or modify a trust, is a claim that triggers prong one of the California anti-SLAPP statute Cal. Code Civ. Proc. §425.16, which means that the party seeking to claim and enforce that the no contest clause was triggered must be prepared to satisfy prong two of the anti-SLAPP statute which requires him to sufficiently establish a reasonable possibility of prevailing on the claim that the no contest clause was triggered and violated.

Takeaway. If you bring a claim to enforce a no contest clause based on an opposing party’s prior petition filed in probate, you must be prepared at the time of your filing to establish to the court, based on evidence and declarations, that you have a reasonable possibility of prevailing on your claim that the other party had triggered and violated the no contest clause.

Urick is also interesting for the court’s discussion whether the previously filed petition to reform or modify the trust triggered the no contest clause, including the discussion whether that previously filed petition was filed by the petitioner as a beneficiary of the trust or as the trustee of the trust and whether there was really a distinction that mattered under the facts of the case.

Other thoughts about the anti-SLAPP statute. I have been involved in Cal. Code Civ. Proc. §425.16 motions. It is my opinion that it is a deeply flawed statute except possibly in really obvious and clear situations and in those cases the party who has those defenses has other remedies such as a demurrer, motion to strike, or motion for summary judgment or summary adjudication. The anti-SLAPP statute should be revoked or very significantly amended and limited. To add further injury, the filing of an anti-SLAPP motion automatically stays all discovery unless a motion to allow and compel discovery is brought and the court grants that motion – thus, strategically a party might bring an anti-SLAPP motion simply to see if they can prevail even if their arguments and chances of prevailing are not good – and the statute further provides that if a party prevails on an anti-SLAPP motion they are entitled to attorneys’ fees whereas if a party defeats an anti-SLAPP motion the statute does not provide that they are entitled to recover attorneys’ fees. The anti-SLAPP statute is ripe for abuse or use in situations that might be counter to other public or judicial policies, which the court in Urick appeared to recognize, but as the court noted, nevertheless the statute is still on the books and is applicable unless and until the Legislature does something about the statute.

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New FinCEN and Consumer Financial Protection Bureau Memo re Efforts to Combat Elder Financial Exploitation

At the bottom of this post you will find a link to a new Financial Crimes Enforcement Network (FinCEN) and Consumer Financial Protection Bureau memorandum about efforts to combat elder financial exploitation, which the memo identifies as the illegal or improper use of an older person’s funds, property or assets. And I have also included additional links below. As the memo notes, “Financial institutions can play a key role in detecting, responding to, and preventing EFE [Elder Financial Exploitation]. The memo also encourages collaboration between financial institutions, law enforcement and APS [Adult Protective Services]. This is a topic that I have handled in many actual cases, and about which I have given presentations and written blog posts. I have also seen a recent article discussing the rather large percentage of incidents in which physical elder abuse is not reported by medical facilities such as hospitals.

It has long been my view that the collaboration effort must also include private attorneys, for the simple reason that law enforcement and APS simply do not have the resources to handle the numbers of cases, or how long it takes to prosecute them to obtain recovery. Reporting is one thing, prosecuting the cases is an entirely different matter. Law enforcement and APS are not staffed to obtain recovery through the court system. The district attorney and attorney general are staffed to prosecute these cases through the court system, but again, the resources available are inadequate. These cases can involve complicated legal and evidentiary issues including mental capacity, undue influence, dependence, consent, fiduciary and other duties, burden of proof, etc.

In addition to the below link to the FinCEN/Financial Protection Bureau memorandum, I have also provided below a few links to some of my prior posts on this topic and elder abuse.

Best regards, David Tate, Esq., Royse Law Firm, Menlo Park office, http://rroyselaw.com/

http://files.consumerfinance.gov/f/documents/201708_cfpb-treasury-fincen_memo_elder-financial-exploitation.pdf

Elder Abusers Use The Legal System Also – Video http://wp.me/p1wbl8-jp

Elder and Dependent Adult Resources are Ridiculously Inadequate and Archaic http://wp.me/p1wbl8-cV

Elder Abuse and Protection Slides 2015 http://wp.me/p1wbl8-dm

Counties Need to Refer Elder Abuse Cases to Private Attorneys – Video http://wp.me/p1wbl8-ke

Everyday is elder abuse prevent day – cartoon video http://wp.me/p1wbl8-lE

What documents does a trustee provide relating to the Probate Code §§16060.5, 16061.7 and 16061.8 notice requirements?

The following discussion is about the requirements of California Probate Code §§16060.5, 16061.7 and 16061.8, and what documents must be provided by the trustee if the trustee voluntarily provides copies of documents, such as with the section 16061.7/16071.8 notice, or if a beneficiary or heir requests copies of documents. Upon request, or voluntarily if the trustee so elects, the trustee is required to provide copies of the terms of the trust. Below I have copied and pasted parts of a legal discussion on this topic, without the specific facts of the situation – so the below discussion is rather dry, but you can envision that documents and what they say can and will vary from case to case. Immediately below is an overall summary based on reading the statutes, case law, and legislative committee history. Further below I have summarized the statutes, a few cases on legislative intent, and some of the legislative committee comments.  You can ignore the underline and bold in the below materials – those were added in the original materials, but they are not necessarily relevant for this discussion. Fun reading. This is or should be an important topic of discussion for trustees, beneficiaries, estate planning attorneys, estate/trust administration attorneys, and Judges. David Tate, Royse Law Firm, Menlo Park Office but with offices in northern and southern California.

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California Probate Code §§16060.5, 16061.7 and 16061.8 provide that a trustee shall provide beneficiaries and heirs with a notice, and with the “terms of the trust” either voluntarily or upon request, and that if the trustee timely and completely does so, beneficiaries and heirs are then required to make a decision whether to contest the trust within the allowable time period. The provisions and requirements of §§16060.5, 16061.7 and 16061.8 are important, and any waiver of the notice and information providing requirement is against public policy, particularly in light of the 120-day limitation deadline for filing a contest action. As no two trusts and trust situations are identical, the application of §§16060.5, 16061.7 and 16061.8, including whether the trustee has satisfied those requirements must be a factual determination that must be made on a case-by-case basis, based on the facts of the case and the requirements of Probate Code §§16060.5, 16061.7 and 16061.8 as provided therein and the legislative intent.

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In relevant part, California Probate Code §16061.7 requires that:

(a) A trustee shall serve a notification by the trustee as described in this section in the following events:

(1) When a revocable trust or any portion thereof becomes irrevocable because of the death of one or more of the settlors of the trust, or because, by the express terms of the trust, the trust becomes irrevocable within one year of the death of a settlor because of a contingency related to the death of one or more of the settlors of the trust.

(2) Whenever there is a change of trustee of an irrevocable trust.

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(b) The notification by the trustee required by subdivision (a) shall be served on each of the following:

(1) Each beneficiary of the irrevocable trust or irrevocable portion of the trust, subject to the limitations of Section 15804.

(2) Each heir of the deceased settlor, if the event that requires notification is the death of a settlor or irrevocability within one year of the death of the settlor of the trust by the express terms of the trust because of a contingency related to the death of a settlor.

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(e) The notification by trustee shall be served by mail to the last known address, pursuant to Section 1215, or by personal delivery.

(f) The notification by trustee shall be served not later than 60 days following the occurrence of the event requiring service of the notification by trustee, or 60 days after the trustee became aware of the existence of a person entitled to receive notification by trustee, if that person was not known to the trustee on the occurrence of the event requiring service of the notification. If there is a vacancy in the office of the trustee on the date of the occurrence of the event requiring service of the notification by trustee, or if that event causes a vacancy, then the 60-day period for service of the notification by trustee commences on the date the new trustee commences to serve as trustee.

(g) The notification by trustee shall contain the following information:

(1) The identity of the settlor or settlors of the trust and the date of execution of the trust instrument.

(2) The name, mailing address and telephone number of each trustee of the trust.

(3) The address of the physical location where the principal place of administration of the trust is located, pursuant to Section 17002.

(4) Any additional information that may be expressly required by the terms of the trust instrument.

(5) A notification that the recipient is entitled, upon reasonable request to the trustee, to receive from the trustee a true and complete copy of the terms of the trust.

(h) If the notification by the trustee is served because a revocable trust or any portion of it has become irrevocable because of the death of one or more settlors of the trust, or because, by the express terms of the trust, the trust becomes irrevocable within one year of the death of a settlor because of a contingency related to the death of one or more of the settlors of the trust, the notification by the trustee shall also include a warning, set out in a separate paragraph in not less than 10-point boldface type, or a reasonable equivalent thereof, that states as follows:

You may not bring an action to contest the trust more than 120 days from the date this notification by the trustee is served upon you or 60 days from the date on which a copy of the terms of the trust is mailed or personally delivered to you during that 120-day period, whichever is later.”

(i) Any waiver by a settlor of the requirement of serving the notification by trustee required by this section is against public policy and shall be void. (Underline and bold added)

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California Probate Code §16061.8 provides that:

“No person upon whom the notification by the trustee is served pursuant to this chapter, whether the notice is served on him or her within or after the time period set forth in subdivision (f) of Section 16061.7, may bring an action to contest the trust more than 120 days from the date the notification by the trustee is served upon him or her, or 60 days from the day on which a copy of the terms of the trust is mailed or personally delivered to him or her during that 120-day period, whichever is later.” (Underline and bold added)

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As used in §§16061.7 and 16061.8, and throughout Article 3 which includes Probate Code §§16060 through 16069, pursuant to Probate Code §16060.5 the term “terms of the trust” means:

“ . . . the written trust instrument of an irrevocable trust or those provisions of a written trust instrument in effect at the settlor’s death that describe or affect that portion of a trust that has become irrevocable at the death of the settlor. In addition, “terms of the trust” includes, but is not limited to, signatures, amendments, disclaimers, and any directions or instructions to the trustee that affect the disposition of the trust. “Terms of the trust” does not include documents which were intended to affect disposition only while the trust was revocable. If a trust has been completely restated, “terms of the trust” does not include trust instruments or amendments which are superseded by the last restatement before the settlor’s death, but it does include amendments executed after the restatement. “Terms of the trust” also includes any document irrevocably exercising a power of appointment over the trust or over any portion of the trust which has become irrevocable.” (Underline and bold added)

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It is well-known that some trustees and trust administration attorneys play games with the statutory notice requirement – some trustees intentionally or by ignorance fail to provide required disclosure or they try to keep the true terms of the trust secret from the recipient beneficiaries and heirs, whereas other trustees and their administration attorneys endeavor to provide full notice and disclosure. One might ask, why would a trustee not provide full disclosure? The answers are simple, for example, the trustee has an ulterior primary motive, or the trustee favors certain beneficiaries or heirs over other beneficiaries or heirs, or the trustee believes that the beneficiary or heir will be less likely to contest the trust if he or she does not have full information, or the trustee is simply mistaken.

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Statutes are to be interpreted in accord with the intent of the Legislature. The fundamental task of statutory construction is to determine and follow the legislative intent so as to effectuate the purpose of the law, including both the policy expressed in its terms and the object implicit in its history should be recognized. Cal. Code Civ. Proc. §1859; People v. Cruz (1996) 13 Cal. 4th 764, 774-775; Walnut Creek Manor v. Fair Employment & Housing Commission (1991) 54 Cal. 3d 245, 268; In re Schaefer (1981) 116 Cal. App. 3d 588, 597. Determining legislative intent is to be the fundamental, cardinal rule of statutory construction. Tyrone v. Kelley (1973) 9 Cal. 3d 1, 10-11.The object that a statute seeks to achieve and the evil that it seeks to prevent are of prime consideration in its interpretation. Sierra Club v. City of Hayward (1981) 28 Cal. 3d 840, 860-861; Dubins v. Regents of University of California (1994) 25 Cal. App. 4th 77, 83. When the Legislature enacts a remedial statute, courts must construe it liberally to promote its purposes, to protect the persons within its purview, and to suppress the mischief within its spirit and policy. Tetra Pak, Inc. v. State Board of Equalization (1991) 234 Cal. App. 3d 1751, 1756. Courts consider legislative history as an extrinsic aid to help elucidate legislative intent. City of San Jose v. Superior Court (1993) 5 Cal. 4th 47, 54; Jevne v. Superior Court (2005) 35 Cal. 4th 935, 948; District of Columbia v. Heller (2008) 554 U.S. 570, 605. Courts also look to legislative history to confirm the Court’s reading of the statute- common sense suggests that inquiry into statutory construction benefits from reviewing additional information rather than ignoring it. Samantar v. Yousuf (2010) 560 U.S. 305, 315-323; Wisconsin Pub. Intervenor v. Mortier (1991) 501 U.S. 597, 611-612 n.4.

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In this case a Senate Judiciary Committee Report with the date September 5, 1997, states (and other Committee Reports similarly state), for example:

“SECTION 23 — Trustee Notification — Probate Code Sections 16061.5 and 16061.7

Existing law requires a trustee, upon reasonable request by a beneficiary, to provide the beneficiary with certain information about the trust and its administration relevant to the beneficiary’s interest in the trust.

This bill would require trustees to notify beneficiaries of a trust by mail or personal delivery when there is a change of trustees and notify beneficiaries and heirs of whom they have actual knowledge when a revocable trust become irrevocable.

The sponsor asserts that the experience of practitioners is that failure to notify beneficiaries of the existence or terms of trusts frequently leads to or exacerbates conflict between trustees and beneficiaries. It is also increasingly common for persons to use revocable as will substitutes. In these cases, the sponsor believes that prompt notification of the heirs of a deceased settlor will reduce the incidence of trustees concealing trust assets and even the existence of trusts.”

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And further, an apparently early in the legislative process or initial Assembly Committee on Judiciary Report also states, for example:

“SEC. 32 & 33 – – Trustee Notification – – Probate Code §§16061.5 and 16061.7

Existing law requires a trustee, upon reasonable request by a beneficiary, to provide the beneficiary with certain information about the trust and its administration relevant to the beneficiary’s interest in the trust. In spite of this requirement, the experience of practitioners is that failure to notify beneficiaries of the existence or terms of trusts frequently leads to or exacerbates conflict between trustees and beneficiaries.

This bill would clarify the statutory mandate on trustees by requiring them to notify beneficiaries of a trust when there is a change of trustees and notify beneficiaries and heirs when a revocable trust becomes irrevocable.”

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The Cal. Probate Code §82 definition of the term “trust” includes “additions thereto”:

California Probate Code §82 states as follows:

(a) “Trust” includes the following:

(1) An express trust, private or charitable, with additions thereto, wherever and however created.

See also Townsend v. Townsend (2009) 171 Cal. App. 4th 389, 405, in which the court held that the Probate Code §82 definition of the term “additionsincludes “additions of property to the Trust.”

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Further, an “instrument” means a will, trust, deed, or other writing that designates a beneficiary or makes a donative transfer. California Probate Code §45.

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Probate Code provisions pertaining to powers of appointment can be found at Probate Code §§600-695, in particular §640 (manifestation of intent), §650 (general power of appointment) and §651 (special power of appointment).

 

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New California trust case holds that a trustee is not liable for personal damages suffered by the beneficiary, and is not liable to the beneficiary if the beneficiary failed to diligently protect her interests

Overview

Williamson v. Brooks holds that a trustee is not liable for personal damages suffered by the beneficiary, and a trustee is not liable to the beneficiary if the beneficiary failed to diligently protect her interests. Williamson v. Brooks, California Court of Appeal, Second Appellate District (2d Civil No. B265745, decided January 31, 2017)

Summary of Facts

In 2008, Dad established an irrevocable Trust which contained five separate Subtrusts benefiting five of his adult children, including Beverly. Dad selected his accountant (Brooks) and his attorney (Clemens) to serve as the initial Co-Trustees. The Subtrust allowed Beverly to withdraw certain portions of the principal at 40, 50 and 60 years of age.

After the Trust was created, Dad and the two Co-Trustees discussed the need to inform Dad’s children about the Trust. Dad said that he wanted to tell them himself and he wanted “to caution [the children] that it was not for purchases [for which] it wasn’t intended.” Dad informed Beverly about her Subtrust on at least two occasions. The first was in a March 22, 2009, email in which Dad responded to an inquiry from Beverly regarding whether accountant Brooks should file Beverly’s 2008 taxes. Dad advised: “[Brooks and Clemens] set up Trusts that do not require you to change any of your tax stuff. File with anyone you like and the Trust Income has no effect on your taxes since each Trust is a separate entity and is taxed on its own. I pay the tax on the Trust. I need to sit with you sometime this year to explain it all.” The second occasion occurred in late spring of 2009 on the beach at Hollister Ranch in Santa Barbara. William again informed Beverly of her Subtrust and told her she would be taken care of in the event of his death.

Subsequently, after Dad later fired Beverly from her employment at Dad’s company Beverly was unable to make the total monthly payments on her home loan. Beverly’s sister offered to help with either the payments in the form of a loan, or by quitclaiming the sister’s partial interest in the property to Beverly so that Beverly could do whatever she wanted with the property, or by having Beverly quitclaiming her interest in the property to her sister, and the sister renting the house back to Beverly. Beverly decided to quitclaim her interest to her sister, and instead moved into Dad’s guest room at Dad’s property at Hollister Ranch – living at Hollister Ranch was a dream come true for Beverly.

In 2012, Beverly contacted accountant and Co-Trustee Brooks for the first time to discuss the Subtrust. Brooks promptly responded, providing the information and documents requested. When Beverly made a request to withdraw assets from the Subtrust in September 2012, “Brooks worked with her to begin making monthly distributions.”

Subsequently Co-Trustees Brooks and Clemens resigned as the Co-Trustees, but for reasons that are not relevant to this case. Successor Trustee Egan filed a first amended petition against Brooks and Clemens for damages suffered as a result of Beverly’s loss of her home property. Egan claimed that Brooks and Clemens breached their fiduciary duties to Beverly by failing to sufficiently inform her of the Subtrust (thus arguably denying Beverly of knowledge of the possibility that payments from the Subtrust might be used to make payments on the mortgage on Beverly’s home, thus preventing Beverly’s loss of that property). Before trial, Joanne Williamson was substituted in as petitioner in her capacity as the second successor Trustee.

The Trial Court ruled in favor of Co-Trustee’s Brooks and Clemens against successor Trustee Williamson. The Court of Appeal affirmed.

Summary of the Court’s Decision

  1. Trustee Not Liable for Personal Damages to the Beneficiary.

Trustees accused of breaches of fiduciary duty may only be held liable for losses to the trust itself, not for personal damages to beneficiaries. “There must be a causal connection supporting any monetary award that the trustee is ordered to pay. [Citation.] Thus, the trustee is only liable for loss or depreciation resulting from the breach of trust, for profits that the trustee made through the breach of trust, or for any profits that would have accrued to the trust but for the breach of trust. Prob. C § 16440 (a).” (2 Cal. Trust and Probate Litigation (Cont.Ed.Bar 2016) § 21.65, p. 21-38, italics added.) See also Estate of Kampen (2011) 201 Cal.App.4th 971, 991-993 (holding that lost opportunity damages are not available as a remedy against a personal representative who had failed to timely distribute estate assets).

  1. No Breach of Fiduciary Duty – Beverly’s Lack of Due Diligence Prevented Her from Learning of the Details of the Subtrust Earlier.

Expert witness attorney Moes, testified that Clemens and Brooks breached their fiduciary duties to keep Beverly reasonably and sufficiently informed of the Subtrust and its provisions. The trial court found, however, that Beverly was informed of her trust shortly after it was created. The Court of Appeal further held:

Williamson maintains that William was required to tell Beverly every detail of her subtrust. We disagree. Beverly was entitled to be informed about her subtrust so that she could take action to gain more information. As stated in Williamson’s opening brief, “The most basic action required of a trustee under the duty to inform is to promptly inform the beneficiary of the existence of the trust and their status as beneficiaries, so that the beneficiary may exercise their rights to secure information about the trust.” The cotrustees fulfilled this duty by ensuring that William informed Beverly of the subtrust, and when Beverly eventually asked Brooks for information regarding the subtrust, he promptly provided it. The trial court found that it was Beverly’s “lack of due diligence” that prevented her from learning the details earlier. The court stated: “I think [Beverly] had real opportunities to inquire about her trust and what income or assets it had. No one appeared to have been hiding the facts from her. She appears to be a very bright and articulate person and the fact that she did not investigate or explore her options [is] inexplicable; that militates against her position.”

Williamson cites no California authority suggesting that a trustee may be held liable for breach of trust or fiduciary duties under the factual scenario presented here. The trial court found that Beverly was made aware of the subtrust shortly after it was created. She understood that Brooks and Clemens were the cotrustees and she had ample opportunity to obtain more information about the subtrust while she was negotiating with Connie and William over the fate of the Via Rosa Property. That she failed to do so does not make Clemens and Brooks liable for breach of fiduciary duty.

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Royse Law Firm – Litigation Update – New California Trustee Liability Case – Employment – Trade Secrets, Etc.

Click on the following link to Legal Updates in Litigation: Royse Legal Updates in Litigation, Liability, Governance & Risk Management (March 10, 2017)

New California case expands shifting trust/trustee attorneys’ fees and costs to a beneficiary’s share of the trust

New California trust dispute decision expands shifting trust/trustee attorneys’ fees and costs to a beneficiary’s share of the trust – Pizarro v. Reynoso, California Court of Appeal, Third Appellate District, Case No. C077594, (March 28, 2017)

Summary. The decision in Pizarro v. Reynoso expands the shifting of trust/trustee attorneys’ fees and costs to a beneficiary’s trust share, and in relevant part reminds us that all trust and estate litigation cases vary and are determined in significant part by the facts and circumstances of that case, the relevant case law, and the discretion of the trial court judge. In Pizarro v. Reynoso, on appeal the Court of Appeal held as follows:

  1. The terms and intent of the trustor prevail in substance – refusing to elevate form over substance the court upheld a sale of the trust real property to a specific beneficiary which the trust authorized in the trustee’s discretion if the beneficiary could afford to purchase the house. The trustee in fact in part assisted the beneficiary in that purchase so that the beneficiary could purchase the property – never the less the court upheld the sale based on substance over form and the intent and terms of the trust.
  2. Under the court’s equitable powers, the attorneys’ fees and costs incurred by the trust/trustee are chargeable against the trust share of a beneficiary who brings an unfounded proceeding against the trust, but those attorneys’ fees and costs cannot be awarded against the beneficiaries other personal non-trust assets, citing Rudnick v. Rudnick (2009) 179 Cal. App. 4th 1328, 1332-1333, 1335, and Estate of Ivey (1994) 22 Cal. App. 4th 873, 877-878, 882-886.
  3. Important – in an expansion of #2 above and charging fees and costs to a beneficiary’s trust share, under those same equitable powers, the court also can award the trust/trustee attorneys’ fees and costs against the trust share of a beneficiary who has not filed or brought a proceed, but who takes an unfounded position and litigates in bad faith causing the trust to incur fees and costs (the beneficiary changed her position to being against the trustee, and in the trial court’s opinion then offered false testimony by declaration, deposition and at trial – offering false evidence in litigation is a bad faith litigation tactic).
  4. The court’s decision also cites or makes reference to California Probate Code §17211(a) and §15642(d), which state as follows (and I have also provided below §17211(b):

17211(a)

(a) If a beneficiary contests the trustee’s account and the court determines that the contest was without reasonable cause and in bad faith, the court may award against the contestant the compensation and costs of the trustee and other expenses and costs of litigation, including attorney’s fees, incurred to defend the account. The amount awarded shall be a charge against any interest of the beneficiary in the trust. The contestant shall be personally liable for any amount that remains unsatisfied.

(b) If a beneficiary contests the trustee’s account and the court determines that the trustee’s opposition to the contest was without reasonable cause and in bad faith, the court may award the contestant the costs of the contestant and other expenses and costs of litigation, including attorney’s fees, incurred to contest the account. The amount awarded shall be a charge against the compensation or other interest of the trustee in the trust. The trustee shall be personally liable and on the bond, if any, for any amount that remains unsatisfied.

15642(d)

(d) If the court finds that the petition for removal of the trustee was filed in bad faith and that removal would be contrary to the settlor’s intent, the court may order that the person or persons seeking the removal of the trustee bear all or any part of the costs of the proceeding, including reasonable attorney’s fees.

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Updated (02172017) California Trustee And Beneficiary Responsibilities And Rights – Please Use It, And Tell Others

Below I have provided a link to my updated (02172017) paper California Trustee and Beneficiary Responsibilities and Rights. Please use it, and pass it along and tell other people who would be interested.

Best to you, David Tate, Esq., Royse Law Firm, Northern and Southern California, 149 Commonwealth Drive, Ste. 1001, Menlo Park, CA 94025, (650) 813-9700, Extension 233, http://www.rroyselaw.com. My practice includes civil and probate court litigation (business, real estate, trusts and estates, employment, IP, D&O, serious personal injury, elder abuse, etc., and representing fiduciaries and beneficiaries, and audit committees and D&O.

Here is the link to the updated California Trustee and Beneficiary Responsibilities and Rights (02172017) a-summary-of-california-trustee-and-beneficiary-responsibilities-and-rights-dave-tate-esq-02172017

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