Eleanor A. Hunter v. Charles M. Hunter, Jr.

CourtCourt of Appeals of Virginia
DecidedOctober 31, 2023
Docket1087221
StatusUnpublished

This text of Eleanor A. Hunter v. Charles M. Hunter, Jr. (Eleanor A. Hunter v. Charles M. Hunter, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Eleanor A. Hunter v. Charles M. Hunter, Jr., (Va. Ct. App. 2023).

Opinion

COURT OF APPEALS OF VIRGINIA UNPUBLISHED

Present: Judges AtLee, Causey and Callins Argued at Norfolk, Virginia

ELEANOR A. HUNTER, ET AL.

v. Record No. 1087-22-1

CHARLES M. HUNTER, JR. MEMORANDUM OPINION* BY JUDGE RICHARD Y. ATLEE, JR. CHARLES M. HUNTER, JR. OCTOBER 31, 2023

v. Record No. 1237-22-1

FROM THE CIRCUIT COURT OF THE CITY OF WILLIAMSBURG AND COUNTY OF JAMES CITY Charles J. Maxfield, Judge Designate

Daniel R. Quarles (George H. Bowles, Sr.; Otey Smith & Quarles; Williams Mullen, P.C., on briefs), for Eleanor A. Hunter, et al.

William W. Sleeth, III (Brett C. Herbert; Gordon Rees Scully Mansukhani, LLP, on briefs), for Charles M. Hunter, Jr.

These cross-appeals concern the effect of “no-contest” provisions in two trust agreements

and related litigation. The parties are the children of the individuals who created the trusts.

Eleanor Hunter1 argues that the circuit court erred when it found that Charles M. Hunter, Jr.

(“Chip”) did not violate the terms of these no-contest provisions. Chip argues that the circuit

court erred in permitting Eleanor to present certain evidence and testimony and in granting her

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 To avoid confusion, we refer to the members of the Hunter family by their first names. request for attorney fees (and denying his own request for the same). For the following reasons,

we affirm.

I. BACKGROUND

Charles M. Hunter, Sr. and Theresa Hunter married in 1953 and had two children,

Eleanor and Chip, as well as one granddaughter. Charles executed a trust agreement in 2010,

naming his daughter, Eleanor, and wife, Theresa, as substitute trustees if he became unable to

serve. Charles died in 2013, at which point all his assets passed outright to Theresa, free of any

trust. Theresa executed a trust agreement in 2011, naming Eleanor as the initial trustee. Her

trust agreement provided that upon the death of both Charles and Theresa, Chip would receive

one-third of the trust assets, minus the value of certain loans previously extended to him, and that

Eleanor and the granddaughter’s trust would each also receive one-third of the trust assets.

Both trust agreements contain no-contest provisions that would revoke a beneficiary’s

interest if they took certain actions.2 Each trust agreement also waived the trustee’s “formal

requirements to inform and report set forth in” former Code § 55-548.13 (current Code

§ 64.2-775).

2 The no-contest provision of Theresa’s trust agreement, which is the relevant, active trust at this point, states

if any beneficiary under this Trust Agreement takes any one or more of the actions described in this paragraph, then the interest of such beneficiary under this Trust Agreement shall be revoked, and such beneficiary shall be deemed to have predeceased me without surviving descendants for all purposes under this Trust Agreement, effective as of the date such action is taken.

One of the “actions” triggering forfeiture was “[c]ontest[ing] any provision of this Trust Agreement,” which includes taking “any action seeking to invalidate, nullify, set aside, render unenforceable, or otherwise avoid the effect of such instrument, action or transaction.” The trust provides a caveat, however, that “a petition made in good faith and not objected to by my Trustee hereunder, seeking an interpretation of this or any other instrument, shall not be considered a contest of such instrument.” -2- Theresa died in 2015, at which point Eleanor began serving as trustee. Sometime

thereafter, Chip allegedly learned of a significant decline in the value of the trust’s assets that he

did not believe was attributable to market forces. In 2017, Chip filed a two-count complaint for

declaratory judgment against Eleanor as trustee and individually. In the first count, Chip sought

a judicial declaration that the second count would not violate the no-contest provisions of the

trust agreements. The second count sought a judicial declaration of the obligations owed by

Eleanor, as trustee, to provide Chip with information and documents relating to the trusts. The

second count provided, however, that the circuit court was to address the second count “[i]f, and

only if,” the circuit court first found that Chip’s second count would not trigger the no-contest

provisions.

Eleanor filed a counterclaim that asserted that Chip’s complaint violated the no-contest

provisions because he sought to avoid the trust agreements’ waiver of the trustee’s

inform-and-report obligations under Code § 64.2-775. She argued that Chip’s complaint violated

the no-contest provisions and that his interests in the trusts were therefore revoked.

Eleanor moved for summary judgment on her counterclaim. In Chip’s brief in

opposition, he contended that the Virginia Uniform Trust Code imposed “non-waivable duties”

on a trustee. Therefore, he argued that “permitting a waiver” of statutory and common law

duties to inform and report and finding that “his efforts to determine his rights” triggered the

no-contest clauses would violate the Uniform Trust Code. After a hearing, the circuit court

found that Chip’s complaint “contested, or sought to invalidate, nullify, set aside, render

unenforceable or otherwise avoid the effect of,” the trust agreements’ waiver of statutory

inform-and-report obligations and thus triggered the no-contest provisions of the trusts.

Therefore, the circuit court granted Eleanor’s motion for summary judgment and held that Chip’s

interest in the Theresa trust was revoked.

-3- Chip appealed to the Supreme Court of Virginia, which found that the circuit court

improperly reached the complaint’s second count without first determining whether doing so

would violate the no-contest provisions. Hunter v. Hunter (Hunter I), 298 Va. 414, 430 (2020).

The Supreme Court reversed the circuit court’s ruling and found that Chip had properly

employed an alternative pleading model as set forth in Virginia Foundation of Independent

Colleges v. Goodrich, 246 Va. 435 (1993), and thus had not triggered the no-contest provision.

Therefore, in finding Chip in violation of the no-contest provisions, the circuit court had

erroneously reached the second count of Chip’s complaint without first addressing the first count

regarding whether his claims would violate the no-contest provisions. Id. at 437. The Supreme

Court briefly discussed, but did not address on the merits, Chip’s argument that “if the

inform-and-report waiver and no-contest provisions were incorrectly interpreted to erect an

impregnable barrier to judicial review of a fiduciary’s duty to inform and report, then neither

provision would be enforceable as a matter of law.” Id. at 436. The Supreme Court noted,

however, that it had “little doubt that this claim, if Chip had pleaded it in his complaint, could

have been challenged as a contest of either the no-contest or the waiver provisions.” Id. The

Supreme Court declined to address it, however, because in employing the alternative pleading

model, “Chip never pleaded that argument, and expressly disclaimed it in his declaratory

judgment complaint.” Id.

On remand, the circuit court granted Eleanor’s motion for leave to file an amended

counterclaim. The amended counterclaim addressed Chip’s arguments concerning the

enforceability of the no-contest provisions, which he had raised in his opposition to her motion

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