In M v. H, the Dutchess County Supreme Court upheld the validity of a trust established by MMH, dismissing claims from several of her children who sought to invalidate it. The ruling, granted summary judgment in favor of AHR, affirming the trust's legitimacy.
MMH, who passed away in 2018, had executed a will and an inter vivos trust that included bequests to her 11 children. The trust specified that 65% of the principal would be bequeathed to her daughter, AHR, while the remaining 35% would be divided equally among her other children. Following MMH's death, five of her children initiated legal action against AHR and the other beneficiaries, seeking to declare the trust invalid and obtain an accounting.
The defendant, AHR, moved for summary judgment, asserting the validity of the trust. The Supreme Court granted tat motion, leading to the plaintiffs' appeal.
On its review, the Appellate Division, Second Department, was of the view that the defendant had met the prima facie burden of proving the decedent's contractual capacity at the time the trust was executed. The court referenced established legal principles, noting that a party's competence is generally presumed, and to invalidate a transfer of property on the grounds of lack of capacity, it must be demonstrated that the party did not understand the nature of the transaction due to mental disability.
The defendant provided substantial evidence, including the trust instrument, deposition testimony, and records from the decedent's attorney, who drafted and oversaw the execution of the trust. This evidence supported the claim that the decedent possessed the necessary contractual capacity.
The plaintiffs failed to present sufficient evidence to raise a triable issue of fact regarding the decedent's capacity or the execution of the trust. Additionally, the defendant demonstrated that the trust was executed in compliance with relevant legal requirements and was not the product of undue influence.
The court acknowledged the potential confidential relationship between the decedent and the defendant but found that this was counterbalanced by evidence of a close family relationship.
The Supreme Court's decision to grant summary judgment in favor of the defendant was upheld, affirming the validity of the trust. The matter was sent back to the Dutchess County Supreme Court for the entry of a judgment declaring the trust valid.
This ruling underscores the importance of clear and compelling evidence in trust and estate disputes, particularly regarding the mental capacity of the decedent and the execution of legal documents. The decision also highlights the court's careful consideration of familial relationships and potential influences in such cases.
When there's a will ... there's a way .....
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DECISION