In Re Estate Of Karen Hurteau, Dana Floth Et Ano, Resp. V. Brandon Donaly, App.

CourtCourt of Appeals of Washington
DecidedMay 17, 2021
Docket81415-0
StatusUnpublished

This text of In Re Estate Of Karen Hurteau, Dana Floth Et Ano, Resp. V. Brandon Donaly, App. (In Re Estate Of Karen Hurteau, Dana Floth Et Ano, Resp. V. Brandon Donaly, App.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Estate Of Karen Hurteau, Dana Floth Et Ano, Resp. V. Brandon Donaly, App., (Wash. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE

In the Matter of the Estate of ) No. 80556-8-I KAREN L. HURTEAU, ) ) Deceased. ) ) DANA FLOTH and MICHELLE ) HURTEAU, ) ) Respondents, ) UNPUBLISHED OPINION ) v. ) ) BRANDON DONALY, ) ) Appellant. ) In the Matter of the GARY L. and ) No. 81415-0-I KAREN L. HURTEAU TRUST, dated ) March 10, 1999. ) ) BRANDON DONALY, ) ) Appellant, ) UNPUBLISHED OPINION ) v. ) ) DANA FLOTH, Trustee of the Gary L. ) and Karen L. Hurteau Trust, ) ) Respondent. )

Bowman, J. — Karen Hurteau died in a house fire, leaving a sizeable

estate. Her daughters Michelle Hurteau and Dana Floth petitioned under the

Trust and Estate Dispute Resolution Act (TEDRA), chapter 11.96A RCW,

alleging Dana’s son Brandon Donaly unduly influenced their mother to name him

Citations and pin cites are based on the Westlaw online version of the cited material. No. 80556-8-I & No. 81415-0-I/2

as the sole beneficiary on two retirement accounts. Brandon then separately

filed a petition under TEDRA to remove his mother as trustee of the Gary L. and

Karen L. Hurteau Trust (Hurteau Trust), alleging she refused to distribute funds

to him. The trust counterclaimed, seeking to disinherit Brandon for violating the

Hurteau Trust’s no contest clause. The trial court concluded that Brandon did not

unduly influence his grandmother but that he acted in bad faith and contrary to

the trust’s no contest clause in seeking to remove Dana as trustee. We affirm.

FACTS

Karen and Gary1 established the Hurteau Trust (Trust) in 1999 and served

together as trustees during their lifetimes. Gary died in 2012 and Karen became

the sole trustee. Karen died on June 11, 2018 in a house fire at the age of 77.

She was survived by her daughters Michelle and Dana as well as Dana’s son

Brandon. At the time of Karen’s death, the Trust was valued at about $3.2

million. Dana, Michelle, and Brandon were the beneficiaries of the Trust.

Separate from the Trust, Karen had two IRAs2 that also designated Dana,

Michelle, and Brandon as the beneficiaries.

After Karen’s death, Dana became the sole trustee of the Trust. The Trust

provided that the trustee must retain its assets until the estate taxes and other

liabilities were determined and paid. It called for a one-year administration

period, during which the trustee had the “sole and absolute discretion” to make

1 We refer to Karen Hurteau, Gary Hurteau, Michelle Hurteau, Dana Floth, and Brandon Donaly by their first names for purposes of clarity and mean no disrespect by doing so. 2 Individual retirement accounts.

2 No. 80556-8-I & No. 81415-0-I/3

distributions to beneficiaries.3 The Trust authorized the trustee to serve,

regardless of any conflicts of interest with beneficiaries. And the Trust included a

strict “no contest clause”:

If any of Trustors’ statutory heirs, and beneficiary mentioned or referred to in this Trust or for whom or for whose benefit Trustors, or either of them, have made any provisions in this Trust, or any other person shall in any manner contest in any court or before any tribunal, this Trust or the validity thereof, or its due and proper execution, or the provisions applicable to him or her, or any other provision of this Trust, or shall in any way question Trustor’s acts in making this Trust or any of its provisions, or file any claim against this Trust exceeding One Hundred Dollars ($100.00) then, in that event, such beneficiary or heir shall forfeit and cease to have any right, title or interest in or any portion of the Trust Estate or any property given under this Trust or any income from such property, and any and all provisions of this Trust in favor of or for the benefit of such beneficiary or heir are revoked.

At the time of Karen’s death, Brandon was one month shy of his 23rd

birthday. Before he turned 35, a “sub-trust” held and administered Brandon’s

share of the Trust. The Trust provision specified that the trustee

shall use so much of the income or principal from the beneficiary’s share as Trustee deems necessary for the beneficiary’s maintenance, education, support and health to the age of [25] considering the availability to the beneficiary of other sources of funds.

At age 25, Brandon would receive “one-third of the net value of the then

remainder of his . . . share.” Then at 30 years old, Brandon would receive one-

half of the net value of his share of the Trust. Finally, at age 35, he would

receive the rest of his share.

3 Such distributions would “be a charge against the share of the recipient who received

the disbursement.”

3 No. 80556-8-I & No. 81415-0-I/4

Brandon was not employed. He had been financially dependent on his

grandmother since 2014. Karen paid Brandon’s rent and utilities and gave him

cars and money. In exchange, Brandon was to help Karen weekly with

groceries, mail, bills, and housekeeping. In the last 37 months of her life, Karen

made $59,800 in check and cash transfers to Brandon.

Dana knew that Brandon was financially dependent on Karen. So within a

week of Karen’s death, Dana in her capacity as trustee requested Brandon’s

lease and financial information so that she could try to disburse money from the

Trust for his living expenses. Despite many requests, Brandon did not send

Dana any documents showing his need. Even so, to ensure that Brandon had

rent money, Dana wrote him a $2,000 check from her personal account as a

“[T]rust advance.”

After Karen’s death, Dana and Michelle learned that Karen changed the

beneficiary designations of both IRAs in the last year of her life. Karen named

Brandon the sole beneficiary. Knowing that their mother had been an infirm and

mostly homebound alcoholic in the year before her death, Dana and Michelle

were concerned that Brandon unduly influenced Karen to change the beneficiary

designations on the accounts.4 Dana and Michelle filed a TEDRA petition

contesting the beneficiary designations and alleging Brandon unduly influenced

Karen over the disposition of the IRAs.

The court set a trial date in December 2018. The court later granted Dana

and Michelle’s motion to amend their complaint and continue the trial to April

4 Even during times of sobriety, Karen’s “ability to process facts or understand what was

happening remained significantly diminished.”

4 No. 80556-8-I & No. 81415-0-I/5

2019. Dana and Michelle’s amended petition included a claim of financial abuse

and exploitation of a vulnerable adult. Brandon did not file an amended answer

to the complaint.

Instead, two months before trial, Brandon separately petitioned under

TEDRA to remove Dana as trustee of the Trust. He alleged that Dana was

“preventing the distribution of any funds from the [T]rust to [him] contrary to [its]

language and intent.” Brandon claimed that Dana was “taking advantage” of his

financial need to “obtain leverage” in her litigation. Shortly after petitioning,

Brandon’s attorney Christopher Lee contacted the Trust’s administrative attorney

with an urgent request for a Trust disbursement because Brandon was facing

eviction. After producing documents showing his need, Dana disbursed funds to

Brandon from the Trust.

While Brandon’s petition to remove Dana as trustee was pending, the

parties engaged in settlement discussions. They reached a resolution but

Brandon later changed his mind. Dana and Michelle moved to enforce the

settlement agreement, which the trial court denied.

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In Re Estate Of Karen Hurteau, Dana Floth Et Ano, Resp. V. Brandon Donaly, App., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-karen-hurteau-dana-floth-et-ano-resp-v-brandon-donaly-washctapp-2021.