Estate Of Eva Ann Sylvester

CourtCourt of Appeals of Washington
DecidedApril 1, 2025
Docket60428-1
StatusUnpublished

This text of Estate Of Eva Ann Sylvester (Estate Of Eva Ann Sylvester) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Estate Of Eva Ann Sylvester, (Wash. Ct. App. 2025).

Opinion

Filed Washington State Court of Appeals Division Two

April 1, 2025

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Estate of: No. 60428-1-II EVA ANNE SYLVESTER,

DAVID SYLVESTERSEN,

Appellant, UNPUBLISHED OPINION

v.

JEANNA ELMER, Personal Representative for the estate of EVA ANNE SYLVESTER,

Respondent.

PRICE, J. — David Sylvestersen appeals the superior court’s denial of his petition to dismiss

the probate of his deceased sister, Eva Sylvester. Sylvestersen argues that (1) the superior court

lacked “jurisdiction” to probate Sylvester’s estate and (2) the superior court abused its discretion

in finding that his petition to dismiss was frivolous and ordering him to pay sanctions. Sylvestersen

requests his attorney fees on appeal.

Jeanna Elmer, the administrator of Sylvester’s estate, responds that Sylvestersen’s appeal

is without merit and requests her attorney fees on appeal.

We affirm the superior court’s denial of the petition to dismiss, but we reverse the award

of sanctions for frivolousness. We deny both parties’ requests for attorney fees on appeal. No. 60428-1-II

FACTS

I. BACKGROUND

In August 2023, Sylvester died intestate when she was a resident of California. Following

her death, Elmer, a family friend, petitioned the Lewis County Superior Court for adjudication of

intestacy and heirship, for letters of administration, and for nonintervention powers. At the time,

Elmer was already serving as administrator of the estate of Sylvester’s mother, Eva Meleskie, who

had died before Sylvester and had left property in Washington. Elmer likely understood, from her

role as the administrator of Meleskie’s estate, that Sylvester would be inheriting money from the

sale of her mother’s property in Washington. Elmer’s petition claimed that Sylvester had property

in Washington that was subject to probate and that her estate was solvent with an estimated value

in excess of $10,000.

The superior court granted Elmer’s petition and appointed Elmer as the administrator of

Sylvester’s estate. The superior court’s order determined the estate to be solvent, directed issuance

of letters of administration, and set a hearing to determine whether granting nonintervention

powers was appropriate.

Sylvestersen apparently learned of the Lewis County petition and, as an heir to his sister’s

estate, sent a letter to Elmer that offered to waive any further involvement with the probate of

Sylvester’s estate in exchange for $75,000.1

1 Our record contains no response from Elmer to this letter.

2 No. 60428-1-II

Several days later, the hearing for granting Elmer nonintervention powers took place. No

one appeared to oppose Elmer’s request for nonintervention powers, and the superior court again

found that Sylvester’s estate was solvent and granted nonintervention powers to Elmer.

Soon thereafter, Sylvestersen filed a petition that requested an inventory and accounting of

the estate’s assets. The petition stated, among other things, that the “[d]ecedent held a substantial

amount of bank deposited funds obtained by inheritance shortly before her death.” Clerk’s Papers

(CP) at 22.

Elmer subsequently filed an inventory and appraisement. The inventory did not reflect any

current assets, but it did explain Elmer’s rationale for filing the probate action in Washington. The

inventory said that the probate action was filed to receive and administer an anticipated distribution

from Meleskie’s probate case and that the anticipated distribution had not yet been received.

Several days later, Sylvestersen sent another letter to Elmer. This time, Sylvestersen

offered to waive any further involvement with the probate in exchange for a payment of $50,000.

In his letter, Sylvestersen provided a list of assets belonging to Sylvester that he knew about,

including a $65,000 inheritance from Sylvester’s mother, Meleskie. Elmer acknowledged receipt

of Sylvestersen’s letter but did not respond to Sylvestersen’s offer to enter into a settlement in

exchange for a cash payment.

II. PETITION TO DISMISS

Shortly thereafter, Sylvestersen filed a “petition to dismiss probate for lack of jurisdiction

and/or insolvent estate and/or revoke nonintervention powers.” CP at 23. Sylvestersen argued

that the primary probate of an intestacy lies with the court of the state in which the decedent was

domiciled and that the “law of domicile” governed the distribution of Sylvester’s assets. CP at 27.

3 No. 60428-1-II

Sylvestersen contended that because Sylvester was domiciled in California and had no property in

Washington at the time of her death, the superior court lacked “jurisdiction” to probate her estate.

CP at 28. He further argued that there was no evidence that Sylvester’s estate was solvent and that

solvency is a prerequisite to granting nonintervention powers.

Elmer responded with a declaration that provided another explanation for why she had filed

a probate in Washington. Elmer said that there were “significant assets for the estate” located in

Washington, including a $65,000 distribution from the “Estate of Eva M. Meleskie to the Estate

of Eva Anne Sylvester.” CP at 34. Elmer claimed the assets were the proceeds of the sale of real

property in the state of Washington that would be distributed to Sylvester. Elmer also contended

that probating Sylvester’s estate in Washington was necessary to provide a way to distribute funds

from Sylvester’s mother’s estate to Sylvester. With her declaration, Elmer filed an amended

inventory and appraisement that, in contrast to the previous inventory, listed $65,000 held in

Elmer’s counsel’s trust account.

The superior court held a hearing on Sylvestersen’s petition to dismiss the probate.

Although his petition had alleged issues with both jurisdiction and solvency, Sylvestersen focused

on jurisdiction at the hearing (and did not expressly argue insolvency). Sylvestersen argued that

“jurisdiction” over the probate of intangible personal property “follow[ed]” the decedent’s

domicile. Verbatim Rep. of Proc. (VRP) at 5. And because the proceeds from the $65,000

distribution were intangible personal property, and Sylvester was domiciled in California at the

time of her death, the superior court lacked “jurisdiction” to probate the estate.

Elmer responded that Sylvestersen’s petition was frivolous. Elmer’s counsel explained

that the $65,000 had “always” been in their trust account and was distributed to Sylvester’s estate

4 No. 60428-1-II

a week earlier.2 VRP at 7. Elmer’s counsel reiterated their position that the probate action was

initiated in Washington “so someone had legal authority to receive and administer” Sylvester’s

inheritance from her mother’s estate and for no other purpose. VRP at 7. Elmer’s counsel noted

that a California probate was unnecessary if the estate did not exceed $185,500 and expressed their

reluctance to litigate in California, stating, “We’re not going to California again. It’s a nightmare.”

VRP at 8. Elmer’s counsel also contended that the estate was solvent because it consisted of

$65,000 and anticipated additional funds in the future.

The superior court denied Sylvestersen’s petition and orally granted Elmer’s request for

attorney fees. When Elmer presented a proposed order that stated that the fee award was based on

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