Bunn v. Delaney

CourtCourt of Appeals of South Carolina
DecidedNovember 22, 2017
Docket2017-UP-434
StatusUnpublished

This text of Bunn v. Delaney (Bunn v. Delaney) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bunn v. Delaney, (S.C. Ct. App. 2017).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE. IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA In The Court of Appeals

Marilyn W. Bunn, a person non compos mentis by and through her guardian, Denise Suddes, and Margaret Bunn Lochmandy, Respondents,

v.

Douglas S. Delaney, as Trustee and in his individual capacity, Alan Wilson, the South Carolina Attorney General, Sacred Heart-Griffin High School, St. Joseph's Home, Quincy University, Notre Dame, The Lawrenceville School, All Saints Catholic Church, and Habitat for Humanity c/o All Saints Catholic Church, Defendants,

Of whom Douglas S. Delaney is the Appellant.

Appellate Case No. 2015-001813

Appeal From Beaufort County Marvin H. Dukes, III, Master-in-Equity

Unpublished Opinion No. 2017-UP-434 Submitted September 8, 2017 – Filed November 22, 2017

AFFIRMED AS MODIFIED

Sean Michael Bolchoz, of Bolchoz Law Firm, PA, of Bluffton, for Appellant. Robert Ernest Sumner, IV and E. Brandon Gaskins, of Moore & Van Allen, PLLC, of Charleston, for Respondent.

PER CURIAM: In this action to remove Douglas Delaney as the independent successor to the corporate trustee of the John M. and Marilyn W. Bunn Charitable Remainder Trust (the Trust), Delaney appeals the master-in-equity's grant of partial summary judgment in favor of Marilyn Bunn (Mother), through her guardian, Denise Suddes (Guardian), and her daughter, Margaret Bunn Lochmandy. Delaney argues the master-in-equity erred in (1) finding no question of material fact existed regarding whether Lochmandy accepted the role of successor individual trustee; (2) finding the terms of the Trust gave Lochmandy and Guardian the authority to remove the successor independent trustee; (3) finding no vacancy occurred in the trusteeship and Lochmandy and Kelly Bunn (collectively, the Daughters) automatically became successor individual trustees upon Mother's incapacity; and (4) disregarding legal presumptions in favor of the nonmoving party. We affirm as modified.1

I. Vacancy in the Individual Trusteeship

Delaney asserts the master-in-equity erred in finding the Georgia probate court's appointment of Guardian did not result in a vacancy in the trusteeship. We agree.

A vacancy in a trusteeship occurs if:

(1) a person designated as trustee rejects the trusteeship;

(2) a person designated as trustee cannot be identified or does not exist;

(3) a trustee resigns;

(4) a trustee is disqualified or removed;

(5) a trustee dies; or

1 We decide this case without oral argument pursuant to Rule 215, SCACR. (6) a guardian or conservator is appointed for an individual serving as trustee.

S.C. Code Ann. § 62-7-704(a) (Supp. 2017). "The cardinal rule of statutory construction is to ascertain and effectuate the intent of the legislature." Hodges v. Rainey, 341 S.C. 79, 85, 533 S.E.2d 578, 581 (2000). "Whe[n] the statute's language is plain and unambiguous, and conveys a clear and definite meaning, the rules of statutory interpretation are not needed and the court has no right to impose another meaning." Id.

Based upon Delaney's failure to present evidence that either Bunn or Lochmandy rejected the trusteeship, the master-in-equity found, "[a]s a matter of law, no vacancy occurred in the present case; and upon the incapacity of [Mother], [the Daughters] became the successor [i]ndividual [t]rustees." The master explained that under section 62-7-704(a), a vacancy occurs upon rejection of the trusteeship by the successor trustee, the resignation of the successor trustee, or the removal of the successor trustee. However, section 62-7-704(a) also provides a vacancy is created upon the appointment of a guardian or conservator for an individual serving as trustee. Therefore, a vacancy was created in the trusteeship when Mother was appointed a guardian.

II. Successor Individual Trustee

Although a vacancy was created upon Guardian's appointment, we find the master-in-equity properly determined the Daughters did not vacate the trusteeship. Thus, the master did not err in finding the Daughters automatically became successor individual trustees upon Guardian's appointment and the Daughters accepted the trusteeship.

A vacancy in a trusteeship of a charitable trust that is required to be filled must be filled in the following order of priority:

(1) by a person designated in the terms of the trust to act as successor trustee;

(2) by a person selected by the charitable organizations expressly designated to receive distributions under the terms of the trust if the Attorney General concurs in the selection; or (3) by a person appointed by the court.

S.C. Code Ann. § 62-7-704(d) (Supp. 2017).

Except as otherwise provided . . . a person designated as trustee accepts the trusteeship:

(1) by substantially complying with a method of acceptance provided in the terms of the trust; or

(2) if the terms of the trust do not provide a method or the method provided in the terms is not expressly made exclusive, by accepting delivery of the trust property, exercising powers or performing duties as trustee, or otherwise indicating acceptance of the trusteeship.

S.C. Code Ann. § 62-7-701(a) (Supp. 2017). "A designated trustee who does not accept the trusteeship within a reasonable time after knowing of the designation is deemed to have rejected the trusteeship." S.C. Code Ann. § 62-7-701(b) (Supp. 2017).

Pursuant to the terms of the Trust, the vacancy created upon Guardian's appointment was required to be filled by the Daughters. The Trust provided the following rules for succession if Mother vacated the trusteeship:

In case of the resignation, refusal or inability to act of either individual trustee, the survivor shall act as the sole individual trustee hereunder. In case of resignation, refusal or inability to act of the survivor of the individual trustee, [the Daughters] shall act as the successor individual co-trustees hereunder. In case of resignation, refusal or inability of either [Lochmandy] or Kelly Kathleen Bunn, the survivor of [Lochmandy] or Kelly Kathleen Bunn shall act as the successor individual trustee hereunder.

Because the Trust did not require any formal action for acceptance of the trusteeship, the Daughters could accept the trusteeship simply by "exercising powers or performing duties as trustee[s], or otherwise indicating acceptance of the trusteeship." See S.C. Code Ann. § 62-7-701(a)(2) (recognizing that "if the terms of the trust do not provide a method or the method provided in the terms is not expressly made exclusive," a person designated as trustee accepts a trusteeship "by accepting delivery of the trust property, exercising powers or performing duties as trustee, or otherwise indicating acceptance of the trusteeship").

Under the Trust agreement, the powers of the individual trustee include the power to "hold, manage, care for[,] and protect the trust property," which includes the power to "[t]o compromise, contest, prosecute[,] or abandon claims in favor of or against the trust." Accordingly, we find the Daughters sufficiently accepted the trusteeship by requesting a trust accounting and trust documents, in continuing to request trust information in anticipation of this action, and in bringing this action. The Guardian's appointment triggered the vacancy in the trusteeship then filled by Lochmandy and Bunn. Delaney contends the Daughters failed to act for over eight months after the Guardian's appointment.

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Related

HOLCOMBE-BURDETTE v. Bank of America
640 S.E.2d 480 (Court of Appeals of South Carolina, 2006)
Hodges v. Rainey
533 S.E.2d 578 (Supreme Court of South Carolina, 2000)
Epworth Children's Home v. Beasley
616 S.E.2d 710 (Supreme Court of South Carolina, 2005)
Bowles v. Bradley
461 S.E.2d 811 (Supreme Court of South Carolina, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
Bunn v. Delaney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bunn-v-delaney-scctapp-2017.