Estate of McClure

CourtColorado Court of Appeals
DecidedOctober 3, 2024
Docket24CA0089
StatusUnknown

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

Bluebook
Estate of McClure, (Colo. Ct. App. 2024).

Opinion

24CA0089 Estate of McClure 10-03-2024

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA0089 Pueblo County District Court No. 23PR30096 Honorable Timothy O’Shea, Judge

In the Matter of the Estate of Jonna Kay McClure, deceased.

Joseph Anthony Lopez,

Appellant,

v.

Stephanie L. Moore,

Appellee.

ORDERS AFFIRMED

Division III Opinion by JUDGE GOMEZ Dunn and Navarro, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced October 3, 2024

William J. Ballas, Pueblo, Colorado, for Appellant

Charles D. Esquibel, Pueblo, Colorado, for Appellee ¶1 In this probate case, Joseph Anthony Lopez appeals the trial

court’s orders rejecting his claim that he was the common law

spouse of the decedent, Jonna Kay McClure, and appointing the

decedent’s sister, Stephanie L. Moore, as personal representative of

the estate. In addition to challenging the trial court’s rulings on the

claimed common law marriage and the appointment of a personal

representative, he also challenges the trial court’s admission of

evidence from the decedent’s former attorney during the

proceedings. We reject Lopez’s challenges and affirm the court’s

orders. However, we deny Moore’s request seeking appellate

attorney fees on the grounds that the appeal is frivolous.

I. Background

¶2 After McClure’s death in 2023, Moore petitioned the trial court

to find that McClure had died intestate and to determine her heirs.

Moore also nominated herself to serve as personal representative of

the estate. In response, Lopez asserted that he was McClure’s

common law spouse and asked that he be appointed as the

1 personal representative.1 The court scheduled a two-day hearing to

resolve the issues.

¶3 Before the hearing, Moore became aware of a “Cohabitation

Agreement” between McClure and Lopez that an attorney had

drafted for McClure before her death. That draft agreement —

which Lopez said he never received and apparently neither he nor

McClure ever executed — provided, in part:

Each of [u]s is an unmarried person. . . . We are not married to each other or to anyone else as of the date of this Agreement. If anyone has ever received any impression by our conduct that we were or are married, it was a misunderstanding. Our cohabitation is an unmarried cohabitation. No marriage between us has existed or is intended to exist under Colorado law or the laws of any other jurisdiction. No future conduct of ours shall be deemed to constitute holding our relationship as a marriage.

1 McClure and Lopez met in 2008, while McClure was married to

John McClure. The McClures divorced in May 2009, and John McClure later passed away. Shortly after the divorce, McClure and Lopez began a romantic relationship, and, in August 2009, Lopez moved in with McClure. They cohabitated from then until McClure’s death about thirteen and a half years later.

2 The draft agreement went on to provide for the parties’ respective

property rights and financial obligations at that time as well as

upon the termination of their cohabitation.

¶4 Moore sought the disclosure of evidence regarding the

attorney’s representation of McClure, and later Moore sought the

admission of that evidence, arguing that it was relevant to whether

McClure believed she was married to Lopez. Lopez objected to both

the discovery and the later admission of that evidence, arguing that

it was protected by the attorney-client privilege. The trial court

overruled both objections, allowed the discovery, and admitted the

evidence at the hearing under the testamentary exception to the

attorney-client privilege.

¶5 During the two-day hearing, the court heard evidence from

both sides, including testimony from Lopez, testimony from several

people who knew McClure and Lopez throughout their relationship,

records of McClure’s and Lopez’s property ownership and tax

filings, and evidence regarding the draft Cohabitation Agreement.

¶6 The court later entered an order finding that the evidence

didn’t clearly establish that McClure and Lopez mutually agreed to

be in a marital relationship and, thus, that they were not common

3 law married. The court therefore determined that Moore had

priority to be appointed as personal representative. Two days later,

the court entered an order appointing Moore as personal

representative and determining McClure’s heirs (who did not

include Lopez). This appeal followed.

II. Common Law Marriage

¶7 Lopez contends that the trial court erred in finding that he and

McClure were not common law married. We disagree.

¶8 “A determination of whether a common law marriage exists

turns on issues of fact and credibility, which are properly within the

trial court’s discretion.” In re Estate of Yudkin, 2021 CO 2, ¶ 16

(quoting People v. Lucero, 747 P.2d 660, 665 (Colo. 1987)).

“Accordingly, we review the [court’s] factual findings for clear error

and [its] common law marriage finding for an abuse of discretion.”

Id. A factual finding is clearly erroneous if it has no support in the

record. Blakeland Drive Invs., LLP IV v. Taghavi, 2023 COA 30M,

¶ 28. And a court abuses its discretion if its decision is manifestly

arbitrary, unreasonable, or unfair or is based on an erroneous

understanding or application of the law. In re Marriage of

Badawiyeh, 2023 COA 4, ¶ 9.

4 ¶9 In Hogsett v. Neale, the supreme court established an updated

test for determining whether a common law marriage exists:

[A] common law marriage may be established by the mutual consent or agreement of the couple to enter the legal and social institution of marriage, followed by conduct manifesting that mutual agreement. The key question is whether the parties mutually intended to enter a marital relationship — that is, to share a life together as spouses in a committed, intimate relationship of mutual support and mutual obligation.

2021 CO 1, ¶ 49. Where there is no evidence of an express

agreement to marry, the court may infer the existence of a marital

relationship from the parties’ conduct. Id. This involves “a flexible

inquiry into the totality of the circumstances that relies on the

factfinder’s credibility determinations and weighing of the evidence.”

Id. at ¶ 50. In particular, a court should consider such factors as

(1) “cohabitation”; (2) “reputation in the community as spouses”;

(3) “maintenance of joint banking and credit accounts”;

(4) “purchase and joint ownership of property”; (5) “filing of joint tax

returns”; (6) “use of one spouse’s surname by the other or by

children raised by the parties”; (7) “shared financial responsibility,

such as leases in both partners’ names, joint bills, or other payment

5 records”; (8) “joint estate planning, including wills, powers of

attorney, [and] beneficiary and emergency contact designations”;

(9) “symbols of commitment, such as ceremonies, anniversaries,

cards, [and] gifts”; (10) “the couple’s references to or labels for one

another”; and (11) “the parties’ sincerely held beliefs regarding the

institution of marriage.” Id. at ¶¶ 55-56.

¶ 10 The trial court applied this test to determine whether McClure

and Lopez were common law married. The court first found “no

evidence in the record reflecting that [McClure] and Lopez ever had

Free access — add to your briefcase to read the full text and ask questions with AI

Related

People v. Thompson
950 P.2d 608 (Colorado Court of Appeals, 1997)
People v. Lucero
747 P.2d 660 (Supreme Court of Colorado, 1987)
Denver National Bank v. McLagan
298 P.2d 386 (Supreme Court of Colorado, 1956)
Bly v. Story
241 P.3d 529 (Supreme Court of Colorado, 2010)
Berra v. SPRINGER AND STEINBERG, PC
251 P.3d 567 (Colorado Court of Appeals, 2010)
Wesp v. Everson
33 P.3d 191 (Supreme Court of Colorado, 2001)
Castillo v. Koppes-Conway
148 P.3d 289 (Colorado Court of Appeals, 2006)
Lawry v. Palm
192 P.3d 550 (Colorado Court of Appeals, 2008)
In re Estate of Owens
2017 COA 53 (Colorado Court of Appeals, 2017)
Calvert v. Mayberry
2019 CO 23 (Supreme Court of Colorado, 2019)
r & Fellman, PC v. Affiniti Colorado, LLC
2019 COA 147 (Colorado Court of Appeals, 2019)
v. Rabin
2020 CO 77 (Supreme Court of Colorado, 2020)
In re Marriage of Hogsett & Neale
2021 CO 1 (Supreme Court of Colorado, 2021)
In re Estate of Yudkin
2021 CO 2 (Supreme Court of Colorado, 2021)
In Re the Matter of the Estate of Ashworth, Robert Harrison
2024 CO 39 (Supreme Court of Colorado, 2024)
George HODGE v. MATRIX GROUP, INC., and Waterpark II & III, LLC
2022 COA 4 (Colorado Court of Appeals, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
Estate of McClure, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-mcclure-coloctapp-2024.