Bank of America v. Koslow

117 Cal. App. 3d 915, 173 Cal. Rptr. 93, 1981 Cal. App. LEXIS 1610
CourtCalifornia Court of Appeal
DecidedApril 10, 1981
DocketCiv. No. 22005
StatusPublished
Cited by3 cases

This text of 117 Cal. App. 3d 915 (Bank of America v. Koslow) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of America v. Koslow, 117 Cal. App. 3d 915, 173 Cal. Rptr. 93, 1981 Cal. App. LEXIS 1610 (Cal. Ct. App. 1981).

Opinion

Opinion

WIENER, J.

Cheryl L. Koslow and Gary L. Effron, beneficiaries of the estate of James Effron, deceased, (Beneficiaries) appeal a probate order denying their application for a citation to remove the Bank of America (Bank) as executor and granting the Bank’s petition for preliminary distribution of statutory attorney’s fees and executor’s commissions.

They challenge on theoretical and practical grounds both customary probate practices fostered by corporate fiduciaries and statutory attorney’s fees. On a theoretical level, they claim as a matter of law statutory attorney’s fees (Prob. Code, §§ 901; 910, subd. (a))1 violate the antitrust laws and their application denies due process of law to those affected. As a practical matter, they question the ethical and legal propriety of what they allege to be the customary practice involving reciprocal back scratching between corporate fiduciaries and lawyers in [920]*920which the lawyer drafting the will is always retained as counsel for the executor. In describing this scenario where the corporation’s only purpose is to perpetuate corporate trust and probate business, they claim a conflict of interest is created causing a breach of the executor’s duty, reflected here by the Bank’s failure to negotiate a lesser fee for its lawyer than that allowed by statute and its failure to discharge counsel when Beneficiaries believed it was in their best interest to do so.

As we will explain, we conclude the system of statutory fees is valid, falling within the state action exemption to the Sherman Antitrust Act enunciated in Parker v. Brown (1943) 317 U.S. 341 [87 L.Ed. 315, 63 S.Ct. 307]. We also decide the Bank did not breach its fiduciary responsibilities. We affirm the order.

Factual and Procedural Background

James Effron died on December 3, 1977.2 On January 30, 1978, the court admitted his April 1, 1974, will to probate and issued letters testamentary appointing the Bank executor. The Bank, as executor, retained attorneys Rose, Jennings, Squires & Jay. Dustin Rose of that firm knew the deceased and prepared his will.

Beneficiaries objected to the Bank’s first account current and petition for payment on account of statutory attorney’s fees and executor’s commissions and for preliminary distribution filed on October 10, 1978. They claimed the Bank and the Rose firm were not entitled to commissions or fees because the California statutory compensation and fee schedules violated due process of law and were contrary to the antitrust laws. The court found their objections to be without merit and allowed $5,000 on account of commissions and fees to be paid to the Bank and to its attorneys.

In the same proceedings, the court also considered the Beneficiaries’ notice of application and application to remove the executor based on grounds similar to those contained in their objections to the preliminary allowance for commissions and fees. The Beneficiaries also argued the [921]*921executor should be removed because the Bank, concerned solely with its self-interest, failed to negotiate with the Rose firm for an attorney’s fee less than that provided by statute. The court rejected Beneficiaries’ arguments and refused to cite the executor. This appeal ensued.3

Statutory Probate Fees

Parker v. Brown Exemption

We first consider whether statutory attorney’s fees violate federal antitrust laws.

The Sherman Act of 1890, enacted to prevent undue restraints upon trade having a significant effect on competition, provides simply, “Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States ... is illegal.” (15 U.S.C. § 1 (1982 pocket supp.) p. 6.) Lawyers can no longer take solace in the naive belief that, as members of a learned profession, they are exempt from the act. “In the modern world it cannot be denied that the activities of lawyers play an important part in commercial intercourse, and that anticompetitive activities by lawyers [922]*922may exert a restraint on commerce.” (Goldfarb v. Virginia State Bar (1975) 421 U.S. 773, 788 [44 L.Ed.2d 572, 585, 95 S.Ct. 2004, 2014].) Although “there may be legal services that have no nexus with interstate commerce and thus are beyond the reach of the Sherman Act” (id., at pp. 785-786 [44 L.Ed.2d at p. 584]), we proceed here on the assumption the fees incurred in probate proceedings, indispensable to the transfer of real and personal property, sufficiently affect commerce to fall within the broad scope of the interstate commerce requirement. (See, e.g., Hospital Bldg. Co. v. Rex Hospital Trustees (1976) 425 U.S. 738, 743-745 [48 L.Ed.2d 338, 343-345, 96 S.Ct. 1848, 1851-1852].)

We also proceed on the premise the setting of fees is a form of price fixing, a practice “conclusively presumed to be unreasonable and therefore illegal without elaborate inquiry as to the precise harm they have caused or the business excuse for their use.” (Northern Pac. R. Co. v. United States (1958) 356 U.S. 1, 5 [2 L.Ed.2d 545, 549, 78 S.Ct. 514, 518].) The fact that statutory attorney’s fees establish a maximum allowance for ordinary services does not alter our premise for “[a]ny combination which tampers with price structures is an unlawful activity.” (U.S. v. Socony-Vacuum Oil Co. (1940) 310 U.S. 150, 221 [84 L.Ed. 1129, 1167, 60 S.Ct. 811, 843].) Agreements to fix maximum prices, “no less than those to fix minimum prices, cripple the freedom of traders and thereby restrain their ability to sell in accordance with their own judgment.” (Kiefer-Stewart Co. v. Seagram & Sons (1951) 340 U.S. 211, 213 [95 L.Ed. 219, 223, 71 S.Ct. 259, 260].)

Within this framework, the applicability of the Sherman Act turns on our determination of whether statutory probate fees fall within the state action exemption of Parker v. Brown, supra.

The Parker court found the California Agricultural Prorate Act, “a program designed to conserve the agricultural resources of the state and to prevent economic waste in the marketing of raisins” (Rice v. Alcoholic Bev. etc. Appeals Bd. (1978) 21 Cal.3d 431, 441 [146 Cal.Rptr. 585, 579 P.2d 476, 96 A.L.R.3d 613]), was exempt from the Sherman Act because the program “derived its authority and its efficacy from the legislative command of the state” (Parker v. Brown, supra, 317 U.S. 341 at p. 350 [87 L.Ed. at p. 326]).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Estate of Getty
143 Cal. App. 3d 455 (California Court of Appeal, 1983)
Trust Services of America, Inc. v. Van de Kamp
143 Cal. App. 3d 455 (California Court of Appeal, 1983)
Estate of Effron
117 Cal. App. 3d 915 (California Court of Appeal, 1981)

Cite This Page — Counsel Stack

Bluebook (online)
117 Cal. App. 3d 915, 173 Cal. Rptr. 93, 1981 Cal. App. LEXIS 1610, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-v-koslow-calctapp-1981.