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.
After the defendant, AHR, moved for summary judgment, asserting the validity of the trust, the Supreme Court granted that motion, leading to the plaintiffs' appeal.
On its review, the Appellate Division, Second Department, was of the view the defendant had met its burden of proving the decedent's contractual capacity at the time the trust was signed. The court referenced established legal principles, noting that a party's competence is generally presumed, and to invalidate a transfer of property on such grounds, it must be shown that the party did not understand the nature of the transaction due to some mental disability.
AHR 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 -- which supported her claim. In addition to being in compliance with relevant legal requirements, AHR also demonstrated that the document was not the product of undue influence, notwithstanding the close relationship with her mother.
Because the plaintiffs failed to competently rebut that proof or to raise an "issue of fact," the Supreme Court's decision to grant summary judgment in the defendant's favor was affirmed.
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