Estate of Carpenter

2017 MT 320N
CourtMontana Supreme Court
DecidedDecember 28, 2017
Docket17-0266
StatusPublished

This text of 2017 MT 320N (Estate of Carpenter) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate of Carpenter, 2017 MT 320N (Mo. 2017).

Opinion

12/28/2017

DA 17-0266 Case Number: DA 17-0266

IN THE SUPREME COURT OF THE STATE OF MONTANA

2017 MT 320N

IN THE MATTER OF THE ESTATE OF ALICE H. CARPENTER,

Deceased.

APPEAL FROM: District Court of the Nineteenth Judicial District, In and For the County of Lincoln, Cause No. DP 14-58 Honorable James Wheelis, Presiding Judge

COUNSEL OF RECORD:

For Appellants:

Robert Terrazas, Elizabeth A. Clark, Attorneys at Law, Missoula, Montana

For Appellee:

Amy N. Guth, Attorney at Law, P.C., Libby, Montana

Submitted on Briefs: November 1, 2017

Decided: December 28, 2017

Filed:

__________________________________________ Clerk Justice Beth Baker delivered the Opinion of the Court.

¶1 Pursuant to Section I, Paragraph 3(c), Montana Supreme Court Internal Operating

Rules, this case is decided by memorandum opinion and shall not be cited and does not

serve as precedent. Its case title, cause number, and disposition shall be included in this

Court’s quarterly list of noncitable cases published in the Pacific Reporter and Montana

Reports.

¶2 Janice Volkmann, Deanna Greenough, Cathy Ness, and Delbert Carpenter

(collectively “Siblings”) appeal the Nineteenth Judicial District Court’s Order enforcing

the “no contest” clause of their mother’s will and awarding the Estate its attorney fees and

costs. We affirm.

¶3 Alice Carpenter (hereafter “Carpenter”) executed a Last Will and Testament on

February 22, 2007. The Will devised Carpenter’s house and a portion of her real property

to her son Lyle and divided her remaining property “in equal shares” to six of her other

children: Janice, Deanna, Cathy, Delbert, Bobbie Ferguson, and Alice Thomas. The Will

named Carpenter’s daughter Connie Tisher personal representative. The Will did not

devise any property to Tisher because Tisher had “already received her bequest . . . in the

land her home sits on.” Carpenter had also assigned Tisher a durable power of attorney in

August 2006, prior to executing her Will. The Will included a provision that if any child

contested it, that child would receive an inheritance of only one dollar.

¶4 Carpenter died in May 2014 at the age of eighty-six. Her death certificate identified

her cause of death as “progressive dementia” with an onset of “> 7 years.” A month after

Carpenter’s death, Tisher filed an application for informal probate of Carpenter’s Will and

2 appointment of personal representative. The District Court granted the application,

admitted the Will to informal probate, and appointed Tisher as personal representative.

¶5 Tisher filed a petition for determination of testacy, for determination of heirs, and

for settlement and distribution of the Estate. Siblings filed a response, alleging that the

February 2007 Will was a “forgery” and that it was not Carpenter’s last valid will and

testament. Siblings asserted that the signature on the Will was forged or that Carpenter

“was not of sound mind, and/or she was under the undue influence of her daughter, Connie

Tisher,” when she executed the Will.

¶6 The District Court issued an order in December 2016 limiting Siblings’ inheritances

to one dollar each because they had contested the Will. The court reasoned, based on the

evidence presented—which included testimony from hearings held and affidavits

submitted after the will contest was filed—that Siblings lacked “probable cause” under

§ 72-2-537, MCA, to challenge the Will’s validity. The court therefore determined that

the Will’s “no contest” clause applied to their inheritances. The court awarded the Estate

its attorney fees and costs under § 72-12-206, MCA. Siblings appeal.

¶7 We review a district court’s findings of fact to determine whether they are clearly

erroneous and its conclusions of law for correctness. In re Estate of Hannum, 2012 MT

171, ¶ 19, 366 Mont. 1, 285 P.3d 463. Siblings argue that the District Court incorrectly

applied the law in determining “probable cause” when it considered facts in the record that

were not known to Siblings at the time they filed their challenge to the Will. They contend

that, under § 72-2-537, MCA, the court’s analysis of Siblings’ probable cause to challenge

the Will should have been limited to the facts known to Siblings at the time they initiated

3 the Will contest. Siblings argue that, based on the information they had when they filed

their challenge, the District Court should have agreed that they had probable cause to

initiate the Will contest. They assert that they reasonably believed that Carpenter either

did not sign her Will or that she lacked testamentary capacity and signed it under undue

influence.

¶8 Section 72-2-537, MCA, provides: “A provision in a will purporting to penalize an

interested person for contesting the will or instituting other proceedings relating to the

estate is unenforceable if probable cause exists for instituting proceedings.” (Emphasis

added). “Probable cause” is a “reasonable belief in the existence of facts on which a claim

is based and in the legal validity of the claim itself.” Black’s Law Dictionary 1395 (Bryan

A. Garner ed., 10th ed. 2014).

¶9 For purposes of this appeal, we assume as valid Siblings’ argument that the District

Court applied the wrong standard under § 72-2-537, MCA, when it considered facts

developed after Siblings filed their challenge to the Will in its determination of probable

cause. Even under this assumption, however, we conclude that the record supports the

District Court’s conclusion that Siblings lacked probable cause to contest the Will’s

validity.

¶10 The record shows that when Siblings initiated their challenge, they were aware of

these facts: Carpenter may have begun to experience dementia when she executed her Will;

some of Carpenter’s children had made observations about Carpenter’s occasional

hallucinations, forgetfulness, and other apparent mental limitations; and Carpenter’s May

2014 death certificate noted that she had “progressive dementia” with an onset of

4 “> 7 years,” suggesting that this onset may have begun before she executed her Will. But

they also knew that Carpenter’s physician had written a letter two months before Carpenter

signed the Will, opining that she was “still medically competent at making [decisions on

her own].”

¶11 Siblings point to their own affidavits that attorney Russell Barnes told Janice and

Deanna in January 2015 that he did not in fact draft Carpenter’s Will and that he did not

recall meeting with Carpenter to prepare her Will; that Barnes showed Siblings a document,

allegedly in Tisher’s handwriting, that contained “a list of word-for-word changes” that

were incorporated into Carpenter’s Will; and that Tisher improperly distributed

Carpenter’s personal belongings after Carpenter’s death. Siblings contend that these facts

supported their beliefs that Carpenter lacked testamentary capacity, that Tisher exercised

undue influence over Carpenter, and that Carpenter’s Will may have been forged.

¶12 Assuming that all of this evidence—even the hearsay—was admissible for the

purpose of determining whether Siblings had probable cause to challenge the Will, it

supports the District Court’s conclusion that they did not. Barnes’s assertion that he did

not recall drafting Carpenter’s Will did not establish a reasonable belief, without any

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Related

In Re the Estate of Hannum
2012 MT 171 (Montana Supreme Court, 2012)
In Re the Estate of Mead
2014 MT 264 (Montana Supreme Court, 2014)
In Re the Estate of Harris
2015 MT 182 (Montana Supreme Court, 2015)

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2017 MT 320N, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-carpenter-mont-2017.