IMO the Estate of Phillip A. Kennedy, Sr.

CourtCourt of Chancery of Delaware
DecidedDecember 30, 2024
DocketROW 162046 DM-MLM
StatusPublished

This text of IMO the Estate of Phillip A. Kennedy, Sr. (IMO the Estate of Phillip A. Kennedy, Sr.) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
IMO the Estate of Phillip A. Kennedy, Sr., (Del. Ct. App. 2024).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

IN THE MATTER ) OF THE ESTATE OF ) ROW Folio No. 162046 DM-MLM PHILLIP A KENNEDY, SR. )

Final Report: December 30, 2024 Date September 10, 2024

FINAL POST-TRIAL REPORT

Bayard J. Snyder, Esquire, SNYDER & ASSOCIATES, P.A., Wilmington, DE; Attorney for Petitioners.

Patricia A. Still, Bridgeville, DE; Pro se Respondent.

MITCHELL, M. This is my ruling following the July 16, 2024, evidentiary hearing regarding

the Estate of Phillip Kennedy Sr. Brothers, Peter Kennedy & Phillip A. Kennedy Jr.

take exceptions to the second and final accounting submitted by their sister, Patricia

A. Still, as the executrix of the estate. They claim Patricia: 1) improperly claimed

commissions for Estate administration; 2) improperly allocated attorney fees to a

beneficiary; and 3) improperly distributed estate funds. For the reasons stated herein,

I find her $2,000.00 commission to be proper, but I do find that she improperly

allocated attorney fees and fees charged by the Register of Wills. I find that the

attorney fees and Register of Wills fees were attributable to the estate and each

beneficiary should have shared in them equally. As such, I am surcharging the

Executrix in the amount of $7,243.53 to correct her actions. This is my final report.

I. BACKGROUND 1

The parties, Peter Kennedy and Phillip A. Kennedy Jr. (together, the

“Petitioners”) and Patricia Still (the “Respondent”), are siblings and the children of

Phillip A. Kennedy Sr. (herein after, the “Decedent”). 2 Phillip Kennedy Sr. passed

away on October 18, 2014. 3 Prior to his passing, the Decedent lived in a home

1 The facts in this report reflect my findings based on the record developed at trial on July 16, 2024. I grant the evidence the weight and credibility I find it deserves. Citations to the record are in the form of Docket Item (“D. I.”) and identified by their entry number. Citations to the trial transcript are in the form of “Tr. __.”. 2 D. I. 3. 3 D. I. 2. located at 2227 Centerville Road, Wilmington, DE, 19808 (hereinafter, “the

Home”).4 He is survived by eight children, Phillip A. Kennedy Jr., Paula M. Wilson,

Patricia A. Still, Pamela J. Giles, Patrick J. Kennedy, Paul J. Kennedy, Phyllis A.

Cuomo, and Peter J. Kennedy.5 The Decedent executed a Last Will and Testament

(“the Will”) dated August 13, 2014, and named his daughter, the Respondent, the

executrix of his Estate. 6

The Will directs the execution of the Decedent’s estate. 7 Relevant here are

Articles 5 and 6 of the Will. Article 5 of the Will directs the executrix to sell all real,

personal, or mixed property for such amounts as the executrix deems best. 8 Article

6 of the Will devises and bequeaths the remainder of the Decedent’s property in

equal shares to his eight children.9

The Register of Wills (“ROW”) granted letters testamentary to the

Respondent on October 30, 2015.10 In accordance with the letters, an initial

inventory was due on or before January 30, 2016, and an initial accounting was due

4 D. I. 9. 5 D. I. 3. 6 Id. 7 Id. 8 Id. 9 Id. 10 D. I. 4.

2 on or before October 30, 2016. 11 Just before the deadline, on January 26, 2016, the

ROW accepted the Respondent’s 60-day extension request to file the initial

inventory. 12 Nonetheless, the Respondent failed to file the inventory by the new

March 31, 2016, deadline. 13 The Respondent also failed to file the first accounting

by the October 30th deadline.14 On November 2, 2016, the ROW notified the

Respondent of the overdue inventory and that a summons may be issued if the

Respondent did not file the inventory by December 2, 2016.15 The Respondent

subsequently filed the initial inventory on December 1, 2016. 16 The initial inventory

valued the Estate at $202,912.09.17 The Home was valued at $192,000.18 The

Decedent’s PNC checking account contained $8,658.49 and there were four

11 Id. 12 D. I. 7. 13 Id. 14 Id. 15 Id. 16 D. I. 8. 17 Id. 18 D. I. 11.

3 insurance policies with a combined cash value of $1,253.60.19 The Decedent also

owned furniture valued at $1,000.20

On March 20, 2017, the Respondent filed the first accounting with the ROW.21

However, the first accounting was not final because the Respondent had not yet sold

the Home. 22 On August 22, 2017, the Respondent signed an agreement with an

auctioneer to auction the Home. 23 On the same day, the attorney for the Estate

claimed unpaid legal fees in connection with the administration of the Estate.24 Eight

days later, the attorney for the Estate withdrew.25 Within a few weeks, the disputes

over the administration of the estate between the parties increased. 26

The Petitioners initially contacted the estate attorney’s office on or around

March 2, 2017 to discuss problems with the estate.27 On September 7th and 11th,

19 D. I. 8 (Schedule C); Respondent’s Post-Hearing Submission, pgs. 21-22 and 38 (Of the $1,253.60, Phyllis Garrett was the beneficiary of $255.87, Pamela Giles was the beneficiary of $346.83, Paul Kennedy was the beneficiary of $344.78, and Peter Kennedy was the beneficiary of $306.12). 20 D. I. 11. 21 Id. 22 Id. 23 D. I. 15. 24 D. I. 12. 25 D. I. 13; Tr. 10:12–15 (At trial, Petitioner testified that she fired the attorney to limit the legal fees). 26 D. I. 14. 27 Petitioner’s Exhibit E. Respondent’s Post-Hearing submission, pgs. 32-33. (Reference to communications with the attorney for the estate include communications with the attorney’s staff. Respondent asserts Petitioner Peter Kennedy mainly communicated with 4 Peter Kennedy contacted the ROW to express concern over the future sale of the

Home and his intent to file a Rule to Show Cause. 28 On September 11, 2017, the

Estate’s prior attorney claimed additional unpaid legal fees related to the

administration of the Estate. 29

On October 30, 2017, the deadline to file the second accounting for the Estate

lapsed.30 The ROW took no immediate action regarding the filing of the second

accounting because a signed agreement to auction the Home was underway, and no

proceeds from the sale could be reported.31 On March 21, 2018, the Home was sold

at auction for $230,000.32 At this time, the Respondent had all the necessary

information to file the second and final accounting. 33 However, she did not file the

accounting because she was disputing the prior estate attorney’s creditor claims for

attorney fees. 34

the paralegal at the attorney’s office, who was a personal friend. See Respondent’s Post- Hearing submission, pgs. 2-3.). 28 Id. 29 D. I. 16. 30 D. I. 18. 31 Id. 32 Id. 33 Id. 34 D. I. 19; Jan. Tr. 6:15–17 (Citations in the form Jan. Tr. – refer to the transcript for the January 24, 2019 hearing.); Tr. 11:6-9.

5 In a letter received by the ROW on May 21, 2018, the Petitioners claimed that

the Respondent was not acting in the best interests of the Estate. 35 In its December

21, 2018 response, the ROW outlined the remaining steps to close the Estate.36 The

ROW gave the Respondent until January 4, 2019 to resolve the disputed creditor

claims.37 When the Respondent did not have this resolved by the deadline imposed

by the ROW, the ROW issued a summons for a Rule to Show Cause Hearing to be

held on for January 24, 2019.38

In response to the Rule to Show Cause hearing being scheduled, on January

17, 2019, the Respondent submitted an incomplete second accounting that failed to

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Related

Wilmington Trust Co. v. Register of Wills in & for New Castle County
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