Estate of Willis

CourtColorado Court of Appeals
DecidedAugust 7, 2025
Docket24CA1276
StatusUnpublished

This text of Estate of Willis (Estate of Willis) 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 Willis, (Colo. Ct. App. 2025).

Opinion

24CA1276 Estate of Willis 08-07-2025

COLORADO COURT OF APPEALS

Court of Appeals No. 24CA1276 Jefferson County District Court No. 12PR30637 Honorable Todd L. Vriesman, Judge

In re the Estate of Marilyn Kay Willis, deceased.

Todd Willis,

Appellant,

v.

Sabrina Willis,

Appellee.

ORDER AFFIRMED IN PART AND REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division V Opinion by JUDGE GROVE Welling and Johnson, JJ., concur

NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced August 7, 2025

Conover Law LLC, Tammy D. Conover, Scott H. Challinor, Greenwood Village, Colorado, for Appellant

Larry D. Harvey PC, Larry D. Harvey, Denver, Colorado, for Appellee ¶1 Todd Willis (Todd)1 appeals the trial court’s order denying his

petition for final settlement of the estate of Marilyn Kay Willis (Kay)

and ruling that the estate inventory should include Kay’s ownership

interests in two pieces of real property. We affirm in part and

reverse in part and remand the case to the trial court for it to

conduct further proceedings consistent with this opinion.

I. Background

¶2 This appeal concerns the disposition of two properties once

owned by Kay and her husband, Ken Willis (Ken). The first is

located on 30th Avenue in Golden (the Golden property). The

second is a duplex on Allison Street in Wheat Ridge (the Allison

property).

¶3 Ken and Kay moved into the Golden property in the 1970s

with their two children, Sabrina Willis (Sabrina) and Todd. In 2009,

they purchased the Allison property for use as a rental. Todd

helped manage this property over the years. Eventually, Todd

1 Because the parties and their deceased parents all share the same

surname, we refer to them by their given names throughout this opinion for clarity. We mean no disrespect by doing so.

1 married and settled in Arvada. Sabrina also lived in the area with

her two children.

¶4 As Ken and Kay grew older, they began having health issues.

Todd assisted his parents and often stayed overnight as their health

declined. Later, he experienced his own health issue and took a

leave of absence from work, lived at the Golden property full time in

2017, and further expanded his role as his parents’ caretaker.

Sabrina also assisted, but not as much as Todd. In 2019, Ken

moved into a nursing home and died the same year. Kay passed in

2020.

¶5 The events underlying this appeal mostly occurred between

2015 and 2020. During this five-year period, as Ken’s and Kay’s

health began declining, they substantially revised their estate plan

through two lawyers, Trace Tyler and Kathryn Kaeble.

¶6 In 2015, after a planning meeting, Tyler drew up estate

planning documents that created the Marilyn Kay Willis Revocable

Living Trust (Trust) as well as “medical” and “general durable”

powers of attorney that authorized Kay to act as Ken’s agent. The

planning documents, which were executed in 2016, provided that

the parents’ assets would be divided equally between their two

2 children. It is undisputed that Ken was incapacitated the next year

and made no decisions regarding the estate after the 2016 will.

¶7 In 2017, Todd became the signer on his parents’ bank

accounts and paid their bills. After Kay suffered a serious fall the

same year, either she or Todd also prepared a document, which we

will refer to as “the revocation,” that stated as follows:

To Whom It May Concern: I, Marilyn Kay Willis, hereby revoke my status as Agent (Power of Attorney) signed January 11, 2016, for Kenneth E. Willis Power of Attorney. The new agent per the Power of Attorney will be Todd Lamar Willis effective July 13, 2017.

The revocation was signed and notarized in July 2017.

¶8 In December 2017, attorney Tyler received an email from Kay’s

email account that requested substantial revisions to the estate

plan.2 The email said that the “new will has been instituted

because of a change in Sabrinas [sic] lack of care or concern in

caring for her parents in their time of need.” The requested

changes included the following, all of which were to “go into affect

[sic] immediately upon the sending of this email.”

2 Sabrina questioned the source of this email at trial, and the court,

too, “reasonably doubt[ed] it was written by [Kay].”

3 • Todd would be the “sole executor of [the parents’] estates

and has full medical [power of attorney] and all other

[powers of attorney] needed for [the parents’] care and the

settlement of [the] estate.”

• If the new will “is Contested the person that contests it

will receive nothing.”

• Some specific personal property was to go to Todd, with

the remainder being split 50/50.

• “All cash and investments will be split 75/25 with 75%

going to Todd and 25% to Sabrina.”

• The Golden property and Allison property were both to be

deeded to Todd — apparently via an inter vivos transfer.

¶9 Tyler met with Kay and Ken sometime in February 2018, and

Tyler subsequently drew up and delivered an amendment to the

Trust and drafted new wills for the couple reflecting the requested

changes. He also drafted a quitclaim deed that purported to

transfer the couple’s jointly held Golden property to Todd upon

execution. He left these documents with Ken and Kay for

execution. In late February, Kay signed them — on her own behalf

4 and, even though she had signed the revocation the year before, for

Ken as well — and had them notarized.

¶ 10 In May 2018, Kay met with attorney Kaeble to discuss

Medicaid asset protection. Kaeble advised Kay that the current

Trust would not “legally hid[e] assets” in order to qualify for

Medicaid.

¶ 11 At the meeting, Kay showed Kaeble the estate planning

documents that had been prepared by Tyler. Among them was the

executed quitclaim deed for the Golden property. Kay told Kaeble

that the Allison property was owned by Willis Properties, LLC, and

that Sabrina owned a ten percent stake in the LLC. But Kay also

said that she wanted to transfer the property in its entirety to Todd.

Kaeble explained that Sabrina would need to be bought out to do

this, and she then prepared an assignment that Sabrina could sign

in exchange for money. Kaeble believed that the family members

would discuss the matter with Sabrina and get back to her. As a

result, Kaeble drafted a revised will that did not reference the two

properties. Kay executed the revised will on May 24, 2018. At the

same time, Kay executed a general durable power of attorney that

named Todd as her agent.

5 ¶ 12 When Ken died in 2019, Kaeble was again contacted to see if

any portion of Ken’s will needed to be probated. At that point,

Kaeble realized that the Allison property had been “jointly owned by

Ken and Kay,” and not by the LLC. Kaeble then drafted a quitclaim

deed that purportedly transferred Kay’s interest in the Allison

property to Todd, who signed the deed as Kay’s agent in June 2020.

¶ 13 After Kay died September 2020, Sabrina petitioned to formally

probate her estate. Todd was appointed personal representative.

He filed an estate inventory that did not include either the Golden

property or the Allison property; later, he filed a petition for final

settlement that valued the estate at $95,720.84. Sabrina objected

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