Faulkner v. Nelson

CourtIdaho Court of Appeals
DecidedSeptember 11, 2024
Docket50937
StatusUnpublished

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

Bluebook
Faulkner v. Nelson, (Idaho Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 50937

In the Matter of The Ron Brown Trust. ) ) BARBARA FAULKNER and BRIAN ) FAULKNER, ) Filed: September 11, 2024 ) Petitioners-Appellants, ) Melanie Gagnepain, Clerk ) v. ) THIS IS AN UNPUBLISHED ) OPINION AND SHALL NOT CLAUDIA NELSON, ) BE CITED AS AUTHORITY ) Respondent. ) )

Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada County. Hon. Gerald F. Schroeder, Senior District Judge. Hon. Christopher Beiter, Magistrate.

Decision of the district court on intermediate appeal from the magistrate court affirming the judgment denying petition for determination of validity of trust, affirmed.

Brian D. Faulkner, Colorado, pro se appellant.

Barbara R. Faulkner, Colorado, pro se appellant

Johnson May; J. Justin May, Boise, for respondent. ________________________________________________

GRATTON, Chief Judge Barbara Faulkner and Brian Faulkner (the Faulkners) appeal from the district court’s order affirming the magistrate court’s judgment denying their petition for determination of validity of trust. We affirm. I. FACTUAL AND PROCEDURAL HISTORY This case involves the creation of a trust by decedent Ronald Brown (Brown) just prior to his death. In December 2020, three days before his death and while on his way to the hospital,

1 Brown went to a lawyer’s office and executed documents creating a trust, transferring assets into the trust and naming Claudia Nelson (Nelson) as the beneficiary. Nelson and Brown met in 2019 and had a romantic relationship. Brian Faulkner (Brian) is a Brown’s nephew, and Barbara Faulkner (Barbara) is Brown’s sister. Prior to execution of the trust, Brian was the sole devisee of a will executed by Brown in 2017. In 2021, the Faulkners petitioned the magistrate court for a determination of the validity of the trust, avoidance of transfer of estate property, and for preliminary injunction or restraining order, claiming Brown was unduly influenced by Nelson in executing a change to his estate plan. After a two-day court trial, at which the Faulkners were represented by counsel, the magistrate court found none of the factors necessary to show undue influence had been proven. The magistrate court entered judgment dismissing the Faulkners’ claims with prejudice. The Faulkners appealed pro se to the district court which affirmed the magistrate court and found there was substantial and competent evidence supporting the determination that Brown was not unduly influenced by Nelson to change his estate plan. The Faulkners appeal. II. STANDARD OF REVIEW For an appeal from the district court, sitting in its appellate capacity over a case from the magistrate court, we review the record to determine whether there is substantial and competent evidence to support the magistrate court’s findings of fact and whether the magistrate court’s conclusions of law follow from those findings. Pelayo v. Pelayo, 154 Idaho 855, 858-59, 303 P.3d 214, 217-18 (2013). However, as a matter of appellate procedure, our disposition of the appeal will affirm or reverse the decision of the district court. Id. Thus, we review the magistrate court’s findings and conclusions, whether the district court affirmed or reversed the magistrate court and the basis therefore, and either affirm or reverse the district court. III. ANALYSIS The Faulkners are appearing pro se on appeal. Pro se litigants are held to the same standards as those litigants represented by counsel. Michalk v. Michalk, 148 Idaho 224, 229, 220 P.3d 580, 585 (2009). Pro se litigants are not excused from abiding by procedural rules simply because they are appearing pro se and may not be aware of the applicable rules. Id.

2 The Faulkners’ appellate claims suffer from several deficiencies. First, the Faulkners fail to include a statement of issues in their brief as required by Idaho Appellate Rule 35(a)(4). The failure of an appellant to include an issue in the statement of issues as required by I.A.R. 35(a)(4) will eliminate consideration of the issue from appeal. State v. Crowe, 131 Idaho 109, 111, 952 P.2d 1245, 1247 (1998). This rule may be relaxed, however, where the issue is argued in the briefing and citation to authority is provided. Id. The Faulkners do not meet the exception to the rule, and as a result, have waived any claim of error on appeal. Second, the Faulkners do not identify the appropriate standard of review. This also effectively precludes review. See Lunneborg v. My Fun Life, 163 Idaho 856, 863, 421 P.3d 187, 194 (2018); State v. Kralovec, 161 Idaho 569, 575 n.2, 388 P.3d 583, 589 n.2 (2017). In their opening brief, the Faulkners make no argument, consistent with the standard of review, that the district court erred in affirming the magistrate court’s decision. While the Faulkners assert error on the part of the district court in their reply brief, this Court will not consider arguments made for the first time in a reply brief. Cummings v. Stephens, 160 Idaho 847, 853, 380 P.3d 168, 174 (2016). Third, the Faulkners argue, for the first time on appeal, that there was fraud upon the court. Generally, issues not raised below may not be considered for the first time on appeal. State v. Fodge, 121 Idaho 192, 195, 824 P.2d 123, 126 (1992). In their reply brief, the Faulkners cite to Idaho Rule of Civil Procedure 60(d).1 Even if we considered this authority despite the Faulkners’ failure to cite it in their opening brief, the Faulkners did not file a motion under Rule 60(d) in the magistrate court. The Faulkners cite no authority for this Court, even if properly raised, to address a Rule 60(d) claim for the first time on appeal. A party waives an issue on appeal if either authority or argument is lacking. Powell v. Sellers, 130 Idaho 122, 128, 937 P.2d 434, 440 (Ct. App. 1997).

1 Idaho Rule of Civil Procedure 60(d)(3) recognizes that courts have the inherent power “to set aside a judgment for fraud upon the court.” The term “fraud upon the court” contemplates more than inter-party misconduct and, in Idaho, has been held to require more than perjury or misrepresentation by a party or witness. It will be found only in the presence of such “tampering with the administration of justice” as to suggest “a wrong against the institutions set up to protect and safeguard the public.” Compton v. Compton, 101 Idaho 328, 334, 612 P.2d 1175, 1181 (1980). (quoting Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 246 (1944)). “The party asserting a claim of fraud on the court must establish that an unconscionable plan or scheme was used to improperly influence the court’s decision and that such acts prevented the losing party from fully and fairly presenting its case or defense.” Rae v. Bunce, 145 Idaho 798, 801, 186 P.3d 654, 657 (2008). 3 Moreover, no issue or argument relative to alleged fraud on the court was raised in the district court on intermediate appeal.

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322 U.S. 238 (Supreme Court, 1944)
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Powell v. Sellers
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State v. Crowe
952 P.2d 1245 (Idaho Supreme Court, 1998)
State v. Fodge
824 P.2d 123 (Idaho Supreme Court, 1992)
Compton v. Compton
612 P.2d 1175 (Idaho Supreme Court, 1980)
Rubin v. American Sportsmen Television Equity Society
254 P.2d 510 (California Supreme Court, 1953)
State v. Sheahan
77 P.3d 956 (Idaho Supreme Court, 2003)
Rae v. Bunce
186 P.3d 654 (Idaho Supreme Court, 2008)
Crowley v. Critchfield
181 P.3d 435 (Idaho Supreme Court, 2007)
Cummings v. No Title Co of Idaho
380 P.3d 168 (Idaho Supreme Court, 2016)
State v. Thomas John Kralovec
388 P.3d 583 (Idaho Supreme Court, 2017)
Lunneborg v. My Fun Life, Corp.
421 P.3d 187 (Idaho Supreme Court, 2018)
Owen v. Smith
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Bluebook (online)
Faulkner v. Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/faulkner-v-nelson-idahoctapp-2024.