Courson v. Simpson

37 Va. Cir. 497
CourtFairfax County Circuit Court
DecidedAugust 4, 1987
DocketCase No. (Chancery) 101095
StatusPublished

This text of 37 Va. Cir. 497 (Courson v. Simpson) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Courson v. Simpson, 37 Va. Cir. 497 (Va. Super. Ct. 1987).

Opinion

By Judge F. Bruce Bach

This matter is before the Court on Defendant Margaret N. Simpson’s motion to set aside the final decree entered in favor of the Complainants on May 15, 1987. The Defendant filed her motion on July 6, 1987.

The essential facts of this case are as follows. Springfield Associates, Inc., made a promissory note naming the Estate of R. C. Nicoll as payee. The Complainants executed a deed of trust on their land to secure the payment of Springfield’s debt. Defendant Margaret N. Simpson, a California resident, is the nonresident Trustee of the Estate of R. C. Nicoll.

The Springfield note became payable on September 30,1986. On January 19, 1987, the Complainants wrote a letter to Ms. Simpson requiring her, as allowed under § 49-25, to bring suit on the Springfield debt. The letter informed her that if she failed to bring suit, the surety or guarantee on the debt would be lost. The letter also informed her that the Complainants had “assigned” sufficient funds to satisfy the debt. Neither Ms. Simpson nor anyone else sued on the debt within the thirty-day period allowed under § 49-26.

On March 24, 1987, the Complainants filed a bill of complaint seeking a declaratory judgment that all rights to proceed against their property under the deed of trust had been forfeited. The bill of complaint also [498]*498sought a release of the deed of trust or a declaration that the Trustee could no longer foreclose. Ms. Simpson was served with process under § 8.01-329. The bill related the Complainants’ belief based on a search of the fiduciary records of Alexandria, Virginia, that Ms. Simpson was the sole surviving trustee. Thus, no other trustee of the Estate was served, nor was any beneficiary served. Ms. Simpson did not answer within twenty-one days. On May 15, 1987, a final decree was entered declaring that the encumbrance was discharged and that the deed of trust was released and directing the Clerk to enter the release in the appropriate records. It is this decree that the Defendant seeks to set aside.

I find that the decree of May 15, 1987, is void for want of service of process on necessary parties. Based on documents filed along with the Defendant’s motion, it appears that a substitute resident trustee was appointed on August 5, 1985. He was not served with process. It is unfortunate that the Complainants were unaware of the existence of the resident trustee. However, trustees are necessary parties in suits affecting the interests of the trust and beneficiaries. Wills v. Chesapeake Western Ry. Co., 178 Va. 314 (1941). Further, it appears that there is a beneficiary who also was not served. Beneficiaries of trusts whose interests may be adversely affected by a suit are also necessary parties, and the failure to join them is grounds to set aside a decree. Simon v. Ellison, 90 Va. 157 (1893). The resident trustee and the beneficiary must be joined.

An issue remains as to whether under § 49-25 notice only to the nonresident trustee was sufficient to invoke the provisions of § 49-26. Section 49-25 allows the “surety, guarantor or endorser, or his committee or personal representative, of any person bound on any contract” to require the creditor or his committee or personal representative to bring suit on the contract. The surety, guarantor, etc., must do this by giving written notice to the creditor after a right of action has accrued on the contract. Section 49-26 provides that the creditor must bring suit against every party to the contract who is a resident of Virginia and solvent within thirty days of being required to bring suit by the notice under § 49-25. If the creditor fails to bring timely suit, he forfeits the right to demand payment from the surety, guarantor, or endorser.

Section 49-25 states only that written notice must be given to “the creditor.” It does not state who “the creditor” is in cases such as this, where there are two trustees with legal title and a beneficiary with equitable title. The Complainants argue that notice to one trustee is notice to all trustees, and that notice only to Ms. Simpson was enough. The Defen[499]*499dant argues that notice must be provided to all trustees and all beneficiaries.

I find that the surety, guarantor, or endorser giving notice under § 49-25 must at a minimum give notice to all persons having legal title to the contract rights. By giving such notice, each trustee is afforded the opportunity to fulfill his fiduciary duties as a trustee. At the same time, this approach avoids the overburdening of the surety, guarantor, or endorser with the duty of finding out who all of the beneficiaries are and providing them with the notice.

This result is consistent with the reasoning of the Court in Davis v. Snead, 74 Va. (33 Gratt.) 705 (1880), that notice under the predecessor statute had to be given to the person with absolute control over the trust, to a party with the power to release the surety, guarantor, or endorser by affirmative act. Under the provisions of this testamentary trust, the trustees were given the power to “manage and control [the] estate and the trust as fully as” the testator, if living, could have. Thus, the trustees together had absolute control over the trust assets, subject only to their fiduciary duties and the general instructions in the will to provide for the support and maintenance of the minor beneficiaries.

Having such extensive control that they could have otherwise voluntarily released the Complainants’ obligation, the trustees were equally capable of releasing the obligation by failing to bring suit against Springfield within the 30-day period allowed under § 49-26. However, for the trustees to release the obligation in any manner, they would have to act jointly. In executing a trust, co-trustees must act jointly unless the trust instrument specifically allows them to act severally. Graeme v. Cullen, 64 Va. (23 Gratt.) 266 (1873). In the case at bar, since only one trustee was joined and so only one trustee failed to sue within 30 days, the obligation could not have been released.

The Complainants knew or should have known that a resident trustee was required. The Complainants’ remedy was to seek the aid of the court of equity to determine whether a resident trustee had been appointed and to appoint one if necessary. The Complainants could then have invoked their rights under § 49-25 and § 49-26 by giving written notice to both trustees requiring them to sue Springfield.

For these reasons, the decree of May 15, 1987, is set aside.

[500]*500By Judge Rosemarie Annunziata

October 18, 1994

The matter before the Court is Herman and Eleanor Courson’s suit to have released a deed of trust encumbering their real property. A civil bench trial in the matter was held on June 7, 1994, after which the Court asked the parties to file briefs in support of their respective positions, and the matter was then taken under advisement.

The following facts are relevant. Plaintiff Herman Courson was the Vice President of a company called Springfield Associates, Inc. On September 30,1981, Springfield executed two notes payable to the order of the Estate of Robert Nicoll (“the Estate”). One of Springfield’s notes, the note at issue in this case, was secured by a deed of trust on the Coursons’ residence.

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Bluebook (online)
37 Va. Cir. 497, Counsel Stack Legal Research, https://law.counselstack.com/opinion/courson-v-simpson-vaccfairfax-1987.