Cloutier

6 Am. Tribal Law 461, 1 M.T.C.R. 50
CourtMohegan Trial Court
DecidedMay 23, 2006
DocketNo. CV-06-0110
StatusPublished
Cited by5 cases

This text of 6 Am. Tribal Law 461 (Cloutier) is published on Counsel Stack Legal Research, covering Mohegan Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cloutier, 6 Am. Tribal Law 461, 1 M.T.C.R. 50 (Mo. 2006).

Opinion

MEMORANDUM OF DECISION

JANE W. FREEMAN, Judge.

The Petitioner, Rebecca Cloutier, has petitioned the Court to authorize the distribution of per capita funds from the trust of her minor child, A.C. The Mohegan Tribe of Indians of Connecticut (“Tribe”) has filed an Answer stating that it supports the Petition, in light of the circumstances of this case.

The Court has jurisdiction of the parties and the subject matter. The minor child, A.C., is a member of the Tribe (Pleading # 105) and the Tribe is a party to the proceeding. The Court has subject matter jurisdiction pursuant to The Gaming Revenue Allocation Plan, MTC SS 2-181-2-187 (the “Plan”). Under MTC § 2-183(h)(5) thereof, the Tribal Court may authorize the trustee or trustees of trusts established for minor children to make distributions to the parents or- guardians of the trust beneficiaries, for the purposes and subjeet to the limitations set forth therein.

[462]*462I. The Gaming Revenue Allocation Plan, MTC §§ 2-1M-2-1H7

As part of the Plan, the Tribe has made provisions for the future welfare of its minor tribal members by contributing their per capita benefits to grantor trusts owned by the Tribe “to be invested, with income on trust principal to be accumulated, for future distribution to those minor tribal members.” MTC § 2-1.81; Scott Quidgeon, Petitioner, In Re: T.T. and T.T. (Minor Children), 1 M.T.C.R 46, 6 Am. Tribal Law 456, 2006 WL 6177326 (2006). While the Plan states that the Tribe shall provide for the future welfare of its minor tribal members, tribal member parents are encouraged to pay for the immediate living needs of their children. MTC § 2-181. No distributions may be made from the grantor trusts until the minor is eighteen years old, except in limited extraordinary circumstances.

All assets accumulated in the grantor trusts for future distribution to a minor tribal member shall be distributed at such time as the minor reaches the age of eighteen (18) and not before, except hi the limited extraordinary circumstances provided in Subsection 2-183(h)(5) (emphasis added).

MTC § 2-181.

The limited extra,ordinary circumstances under which distributions may be made are as follows:

Prior to the time the beneficiary reaches the age of eighteen (18), the Tribal Court may, after careful consideration of he facts, authorize the trustee or trustees of the trust or trusts to make distributions from the trust or trusts to the parents or guardians of the beneficiary only to defray unreimbursed medical expenses or only as necessary to defray expenses for health, education, or welfare incurred by or on behalf of the beneficiary as established by such parents or guardians. Any request for such disbursements shall include a detailed budget of monies necessary for essential living expenses to include health, education, or welfare costs and only upon presentment of a detailed justification for such essential living needs. The petitioning parent or guardian must show, by a preponderance of the evidence, that the amount requested to defray unreim-bursed medical expenses or expenses for health, education or welfare, are reasonable and necessary. The Tribal Court may also require that the petitioning parent or guardian submit receipts of expenditures made from funds disbursed hereunder before any future disbursements are made (emphasis added).

MTC § 2—183(h)(5); see also Scott Quidgeon, Petitioner, In Re: T.T. and T.T. (Minor Children), 1 M.T.C.R. 47, 6 Am. Tribal Law 456, 2006 WL 6177326 (2006); Seidel v. Mohegan Tribe, 1 M.T.C.R 38, 39, 6 Am. Tribal Law 449, 2005 WL 6238704 (2005).

The Tribal Council has expressed a clear intent in the Ordinance to limit distributions from grantor trusts to extraordinary circumstances, where the amounts requested are reasonable and necessary. Further, the Tribal Court is limited to authorizing distributions from trust only where it has made a factual determination that the distributions are “necessary to defray expenses for health, education or welfare incmred by or on behalf of the beneficiary ....” MTC § 2—183(h)(5).

“Extraordinary circumstances” are “[a] highly unusual set of facts that are not commonly associated with a particular thing or event.” Black's Law Dictionary, 7th Ed. “Extraordinary’' has been defined as “going beyond what is usual, regular, common or customary ... exceptional to a very marked extent.” Webster’s [463]*463Third New International Dictionary. “Reasonable” has been defined as “being or remaining within the bounds of reason: not extreme: not excessive”. Id. “Necessary” has been defined as “that cannot be done without: that must be done or had: absolutely required”. Id.

Scott Quidyeon, Petitioner, In Re: T.T. and T.T. (Minor Children), 1 M.T.C.R. 46; Seidel v. Mohegan Tribe, 1 M.T.C.R. 38, 39-40, 6 Am. Tribal Law 449.

II. The Petition and the Facts

The Petitioner is the mother of the minor child, A.C. The Petitioner has requested a distribution from the minor’s trust in the amount of $45,000 to pay for an elevator and other modifications in order to make the family home accessible for the minor child.

A.C. is nine years old and has been diagnosed with Spinal Muscular Atrophy Type II which is a progressive neuromus-cular disorder. She uses a wheelchair for all of her mobility and positioning needs. In addition, the Petitioner uses a lift system to assist her in caring for the minor child. A.C.’s treating physicians and physical therapist indicate that home adaptations are needed to allow for the use of these medical devices; to improve her current quality of life; to provide a more accessible home so that she can be as independent as possible; and to allow her family to more safely care for her.

The Petitioner has contracted to sell her current home, which is slightly under 1200 square feet, because it could not be reasonably adapted to meet A.C.’s medical needs. The Petitioner has also contracted to purchase a new and larger home located on Kitemaug Road in Uncasville (“new home”). The new home is currently under construction; it will include interior and exterior modifications which are needed to allow for the use of A.C.’s wheelchair and to create a more independent living environment for her. When the Petitioner contracted to purchase her new house, construction had progressed to such a stage, that interior and exterior modifications had to be made by the contractor to finished work (“Contractor Modifications”), in order to meet A.C.’s medical needs. These modifications included changing several doorways to make them wheelchair accessible; adding a ramp in the rear of the house; building an elevator pit and shaft; and changing the first floor living room to a first floor bedroom and bath with wheelchair accessibility. The total cost of these Contractor Modifications is $12,975 (Plaintiffs Ex. 7). In addition, Petitioner plans to install an elevator from the basement garage to the first floor, so that A.C. will have wheelchair access to the house. The cost for the purchase of the elevator is $22,684 (Plaintiffs Ex. 6). Therefore, the total of these additional costs to make the new home accessible for the minor child is $35,659.

The Petitioner has requested financial assistance from the Tribe towards the cost of the elevator.

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Cite This Page — Counsel Stack

Bluebook (online)
6 Am. Tribal Law 461, 1 M.T.C.R. 50, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cloutier-moheganct-2006.