In Re Conservatorship of Betty A. Winston

CourtCourt of Appeals of Tennessee
DecidedMay 11, 2026
DocketW2025-00623-COA-R3-CV
StatusPublished
AuthorPresiding Judge J. Steven Stafford

This text of In Re Conservatorship of Betty A. Winston (In Re Conservatorship of Betty A. Winston) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Conservatorship of Betty A. Winston, (Tenn. Ct. App. 2026).

Opinion

05/11/2026

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON January 13, 2026 Session

IN RE CONSERVATORSHIP OF BETTY A. WINSTON

Appeal from the Probate Court for Madison County No. 19-17702 Roy B. Morgan, Jr., Senior Judge ___________________________________

No. W2025-00623-COA-R3-CV ___________________________________

Appellant was named conservator over her mother in 2019 over her sibling’s objection and posted a $25,000.00 surety bond in connection with the conservatorship. After several years in which accountings were approved by the trial court, a new judge was designated to preside over the case. The new trial judge refused to approve several of the expenses in the later accountings, finding that they were either not for the benefit of the ward or constituted payment to the conservator without prior court approval. As a result, the trial court ruled that the conservator was required to reimburse over $30,000.00 in expenses to the conservatorship account. Appellant argues that the trial court erred in finding that these expenses were unauthorized and directing reimbursement, as well as in granting a judgment to the conservator’s surety for the amount it paid to reimburse the conservatorship account pursuant to the surety bond. Discerning no reversible error, we affirm.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Probate Court Affirmed and Remanded

J. STEVEN STAFFORD, P.J., W.S., delivered the opinion of the court, in which JOHN W. MCCLARTY, P.J., E.S., and VALERIE L. SMITH, J., joined.

Alison Winston, Jackson, Tennessee, Pro Se.

Vincent K. Seiler, Jackson, Tennessee, for the appellees, Russell Winston and Andrea Lewin.

Charles H. Barnett, IV, Jackson, Tennessee, for the appellee, Sara E. Barnett, Substitute Conservator.1

1 Charles Barnett filed a notice of appearance in this matter on December 15, 2025. Sara Barnett filed her brief pro se and was the attorney who appeared at oral argument. Melissa Jane Lee, Jennifer Sherman Schnall, and Catherine C. Farone, Nashville, Tennessee for the appellee, State Farm Fire & Casualty.

OPINION

I. FACTUAL AND PROCEDURAL BACKGROUND

In February 2019, Petitioner/Appellant Alison Winston (“Appellant”) filed a petition to establish a conservatorship over her mother, Betty A. Winston (“Ward”) in the Madison County General Sessions Court, Probate Section (“the trial court”), with Chancellor James F. Butler presiding by interchange. A guardian ad litem was appointed for Ward; Appellant’s sister, Appellee Andrea Lewin, eventually filed a motion to intervene and a counterpetition, asking that a public conservator be appointed. Following a hearing, the trial court appointed Appellant to serve as conservator in May 2019.2 Per the court’s order, Appellant obtained a bond in the amount of $25,000.00 from Appellee State Farm Fire and Casualty Company (“State Farm”) as surety. Appellant filed a property management plan in July 2019. The plan detailed certain expenses that were owed monthly by Ward, including a home mortgage, two unsecured loans, a car loan, utilities and cable television, healthcare expenses, car insurance, food, and transportation. The plan did not include any provision permitting Appellant to reimburse herself for any expenses or to compensate her for her services without court approval.

In the years that followed, Appellant filed periodic accountings with the trial court, all of which were approved by both Chancellor Butler and a successor trial court judge.3 Relevant to this appeal, Appellant submitted one such accounting on August 3, 2023.4 Although a hearing was scheduled on this accounting for April 5, 2024, the accounting was not at that time approved. Instead, Chief Justice Holly Kirby entered an order on May 6, 2024, designating Senior Judge Roy B. Morgan Jr. to hear this case “to its conclusion[.]” A hearing before Judge Morgan was thereafter scheduled for June 7, 2024, by which time Appellant had submitted another accounting.5 According to Appellant, Judge Morgan “undertook a much more inquisitive review of Appellant’s accounting than previously exercised by Chancellors Butler and Maroney.”

Following the June 7, 2024 hearing,6 the trial court entered an order finding that Ward died in May 2024 and directing Appellant to file a final accounting. In reviewing the

2 The trial court’s decision to appoint Appellant as conservator was affirmed by this Court on August 6, 2020. See In re Conservatorship of Winston, No. W2019-01134-COA-R3-CV, 2020 WL 4556830 (Tenn. Ct. App. Aug. 6, 2020). 3 Following Chancellor Butler’s retirement, Chancellor Steven W. Maroney was appointed to fill his vacancy. 4 This accounting covered January 2023 through June 2023. 5 This accounting was filed in April 2024 and covered July through December 2023. 6 No court reporter was present for this hearing or for any of the later hearings at issue in this case. -2- April 2024 accounting, the trial court found several actions taken by Appellant over the life of the conservatorship to have been without prior court authorization, including (1) placing herself as a co-owner, with the right of survivorship, over Ward’s Regions Bank account; (2) preparing a quitclaim deed conveying an ownership interest in Ward’s home to herself and having the deed signed by Ward; (3) refinancing the mortgage on the home and using the funds to pay Ward’s credit card debts; (4) using Ward’s funds to pay Appellant compensation as conservator and to pay Appellant’s “own personal expenses”; and (5) assisting Ward in creating a trust. The trial court therefore ruled that it was unable to approve the accounting without a further hearing and review of documents. Appellant was directed to submit a final accounting and other documents to support her actions.

Appellant filed the requested documents on July 1, 2024. A second hearing was held on July 22, 2024. In its July 23, 2024 order, the trial court explained that it was addressing only the two most recent accountings, covering July through December 2023 and January through May 2024.7 As an initial matter, the trial court noted that Tennessee law provides that “[n]o compensation to the fiduciary shall be paid without prior court approval.” Tenn. Code Ann. § 34-1-112(c). After hearing Appellant’s testimony, the trial court ruled that Appellant “breached her fiduciary relationship as to some expenditures because such were not expenditures for the benefit or protection of [Ward], or were compensation without prior court approval.” The trial court listed each improper expenditure separately, totaling $14,028.84 from the 2023 accounting8 and $8,000.00 from the 2024 accounting.9

The trial court also explained that Appellant breached her fiduciary duty in placing herself on Ward’s bank account rather than establishing a conservatorship account, preparing a quitclaim deed transferring property from Ward to herself, and preparing the documents necessary to establish the living trust. The trial court further ruled that some “Payoffs and Payments” from the refinancing of the mortgage were for the benefit of Appellant and ordered her to repay $2,380.79 for those payments. The trial court accordingly approved the two accountings with the exception of the above expenditures and ordered Appellant to reimburse the conservatorship account in the amount of $24,409.63 and to prepare a final accounting.

The trial court held a separate hearing in order to approve the accounting that covered January 2023 to June 2023.

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Bluebook (online)
In Re Conservatorship of Betty A. Winston, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-conservatorship-of-betty-a-winston-tennctapp-2026.