Estate of Rose Litoff

CourtCourt of Appeals of Texas
DecidedApril 29, 2014
Docket05-13-00556-CV
StatusPublished

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

Bluebook
Estate of Rose Litoff, (Tex. Ct. App. 2014).

Opinion

AFFIRM; and Opinion Filed April 29, 2014.

S Court of Appeals In The

Fifth District of Texas at Dallas No. 05-13-00556-CV

IN RE ROSE LITOFF

On Appeal from the Probate Court No. 3 Dallas County, Texas Trial Court Cause No. 95-00016-P3

MEMORANDUM OPINION Before Justices Bridges, O’Neill, and Brown Opinion by Justice O’Neill This is the second appeal involving Robert Litoff, Eliot Litoff, and the estate of their

deceased mother, Rose Litoff. In the first appeal, we determined the district court did not have

jurisdiction to consider and enforce a settlement agreement concerning Robert Litoff’s one-

fourth interest in Rose’s estate because the administration of her estate was still pending in

probate court. See Litoff v. Litoff, No. 05-07-01242-CV, 2009 WL 456682, at *1 (Tex. App.—

Dallas Feb. 25, 2009, no pet.) (mem. op.).

Rather than filing his dismissed lawsuit in the probate court, Robert filed a “petition,

motion to remove independent executor or, in the alternative, motion to show cause for bond”

against Eliot. 1 The probate court determined Robert was no longer an interested party in the

estate based on the settlement agreement and, therefore, did not have standing to pursue his

claims. The probate court then dismissed the case. 1 Eliot was a named co-executor of the estate. In two issues, Robert argues the probate court erred by failing to follow “this Court of

Appeals guidance” in the first appeal and by concluding he is not an interested party with

standing to pursue his claims. We affirm the trial court’s judgment.

Background

Administration of Rose’s estate began in January 1995 in Dallas County Probate Court

No. 3. The administration was ongoing in May 2003 when Robert and Eliot, voluntarily and

independently from the court proceedings, mediated a dispute over Robert’s interest. The

mediation resulted in a settlement agreement in which Eliot agreed to purchase Robert’s one-

fourth interest in the estate if that interest had not been distributed to Robert by December 31,

2004.

When no distribution had occurred and it became apparent administration of the estate

would not be finalized by the end of 2004, Eliot attempted to purchase Robert’s interest pursuant

to the settlement agreement. Robert refused, arguing Eliot’s request for him to sign an additional

document was “non-bargained additional consideration.” Robert then filed a breach of contract

suit in district suit.

Robert later argued the district court did not have jurisdiction over the matter and filed a

motion to dismiss or transfer the case to probate court. The district court denied the motion,

signed a judgment enforcing the settlement agreement, and transferred Robert’s one-fourth estate

interest to Eliot. It is undisputed Eliot paid Robert a little over $214,000 for the estate interest.

Robert then appealed and this court vacated the trial court’s judgment enforcing the

agreement and dismissed the case because the district court did not have jurisdiction when

Rose’s estate was still under administration in the probate court. Litoff, 2009 WL 456682, at *1.

The record does not indicate that Robert refiled his breach of contract claim against Eliot in the

probate court. Rather, the petition filed with the probate court is titled “petition, motion to

–2– remove independent executor or, in the alternative, motion to show cause for bond” in which

Robert argued Eliot (1) paid himself a fee in violation of the probate code; (2) Rose’s estate was

harmed by his gross misconduct and mismanagement of the estate in various ways; and (3) he

engaged in self-dealing. 2 He argued Eliot should be removed as co-executor or in the alternative,

Eliot should be required to appear and show cause as to why he should not be required to post a

corporate bond in the amount of “not less than $5,000,000” to protect the estate. Eliot filed a

motion in limine to dismiss the petition because based on the settlement agreement and Robert’s

relinquishment of his one-fourth interest in the estate, Eliot argued Robert was no longer an

interested party in the estate and lacked standing to pursue his claims.

The probate court held a hearing on April 15, 2013 to determine whether Robert had

standing to pursue his “amended petition/motion to remove independent executor, or in the

alternative, motion to show cause for bond.” At the hearing, the court took judicial notice of

Robert’s original petition filed in the district court in 2005 in which he stated, “Plaintiff Mr.

Robert Litoff has fully performed his obligations under the Settlement Agreement. And in

accordance with the terms of the contract, the Plaintiff Mr. Robert [Litoff] sold his one-fourth

interest in the estate of defendant.” Robert further admitted to cashing a check for approximately

$214,000 from Eliot and not returning the money even after this court vacated the district court’s

judgment because it lacked jurisdiction. When asked if he had ever contested the validity of the

settlement agreement, Robert answered, “Um, I did not like it. I was not well at the time.”

However, because he was a beneficiary under the will, Robert continued to argue, despite the

settlement agreement, that he had standing to bring his claims against Eliot. The probate court

disagreed and ruled Robert lacked standing to pursue his claims. This second appeal followed.

2 Robert later filed a second amended petition alleging the same causes of action.

–3– Reliance on This Court’s Prior Judgment

In his first issue, Robert argues the probate court failed to follow “this Court of Appeals

guidance and judgment in Case No. 05-07-01242-CV” . . . which is “directly on point related to

these parties and their disputed issues.” We disagree with Robert’s characterization of our prior

opinion and judgment.

In the first appeal, the issue before us was whether the district court had jurisdiction over

the breach of contract claim involving the settlement agreement between the brothers. Litoff,

2009 WL 456682, at *1. Our discussion of the settlement agreement was limited to determining

whether jurisdiction was appropriate in the district court. Id. at *2. Because the settlement

agreement concerned distribution of Robert’s share of the estate, we concluded the suit to

enforce the settlement agreement was a “probate” matter “appertaining” or “incident” to the

estate. Id. Thus, under the applicable sections of the probate code, the probate court was the

proper court for the suit rather than the district court. Id.

While our judgment “vacate[d] the trial court’s judgment enforcing the agreement,” it

was the necessary disposition because the trial court was without jurisdiction to enforce the

agreement. By vacating the enforcement of the agreement, we did not in any way consider or

rule on the validity of Robert’s arguments concerning the settlement agreement. We simply

addressed the jurisdictional issue and appropriately dismissed the case. Id. Thus, Robert’s

contention that the judgment from the first appeal somehow supports his standing argument is

without merit.

Moreover, his contention that the first appeal and the present appeal “relate to the same

matters” is incorrect. Robert’s suit in the district court involved enforcement of the settlement

agreement based on a breach of contract. The record does not indicate he refiled that claim in

the probate court after dismissal.

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