In Re: Estate of Lorraine McKitrick

CourtCourt of Appeals of Georgia
DecidedMarch 28, 2014
DocketA13A2351
StatusPublished

This text of In Re: Estate of Lorraine McKitrick (In Re: Estate of Lorraine McKitrick) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia 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 Lorraine McKitrick, (Ga. Ct. App. 2014).

Opinion

WHOLE COURT

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

March 28, 2014

In the Court of Appeals of Georgia A13A2351. IN RE: ESTATE OF LORRAINE McKITRICK.

MCFADDEN, Judge.

This appeal, filed on behalf of Lorraine McKitrick, an incapacitated adult (“the

Ward”),1 by attorneys she retained shortly before she was adjudged incompetent,

seeks review of two orders entered by the probate court. Specifically, she first

challenges the probate court’s finding that the conservator appointed for her estate did

not have a conflict of interest that resulted in harm to the Ward. But because the Ward

failed to include the transcript of the hearing at which this issue was addressed and

1 See OCGA § 29-5-20 (a) (5) (“In every conservatorship the ward has the right to: . . . Individually, or through the ward’s representative or legal counsel, bring an action relating to the conservatorship, including the right to file a petition alleging that the ward is being unjustly denied a right or privilege granted by Chapter 4 of this title and this chapter and the right to bring an action to modify or terminate the conservatorship pursuant to the provisions of Code Sections 29-5-71 and 29-5-72[.]”) evidence presented, we must affirm. The Ward also challenges the court’s order

establishing the hourly rate that counsel for the Ward could bill for legal fees to be

paid by the conservator. We vacate the probate court’s order establishing the hourly

rate and remand for the court to consider evidence on the issue.

The record reveals that on January 4, 2013, prior to a determination that she

was incapacitated, McKitrick retained counsel to represent her in “Cobb County

Probate case #12-1853.” It is undisputed that on February 20, 2013, however, the

probate court appointed McKitrick’s son, Thomas Richardson, to serve as her

conservator, and her daughter, Mary Mellom, to serve as her guardian.2 While it is not

included in the record here on appeal, the parties do not dispute that around March

11, 2013, Richardson, as conservator, filed a “Petition to Maintain Previously

Established Estate Plan and for Continuing Powers to Invest.” The Ward objected that

her son Richardson should be removed as conservator because his ownership interest

in her assets created a substantial conflict of interest that caused her harm.

On April 29, 2013, the probate court held a hearing on the matter during which

the “question of counsel’s authority to serve as counsel for the Ward” was also

2 It appears that the probate court also appointed a guardian ad litem for the Ward.

2 raised.3 Two days following the hearing, counsel for the Ward filed a “Notice of

Intent to Continue as Ward’s Attorney,” asserting that because the Ward hired

counsel prior to the capacity hearing, he intended to continue to represent her

interests. On May 17, 2013, the probate court entered orders addressing these issues,

and it is from these rulings that the Ward appeals.

1. Conservator’s conflict of interest.

The Ward complains that her conservator, because of his conflict of interest,

“should either step down or divest himself of the ownership of the assets of the

Ward’s estate.” She complains that the conservator refused to “spend any of the

corpus of the Estate on the items that the Ward desires,” and “has been dilatory in

paying necessary items.” The conservator responds that the evidence presented at the

hearing on this matter reveals that his judgment is not clouded, that he has sought

authority for all necessary expenditures as well as items and services requested by the

Ward, and that the evidence showed nothing other than that he has been carefully

conserving the Ward’s assets and paying for her care. The probate court ruled that

although the conservator had a conflict of interest as a result of his potential death

3 A transcript of this hearing was not included in the record here on appeal.

3 benefit in the Ward’s accounts, there was no showing that the conflict had resulted

in harm to the Ward.

OCGA § 29-5-24 (b) provides:

The conservator must disclose promptly any conflict of interest between the conservator and the ward when it arises or becomes known to the conservator. The conservator must seek the court’s determination as to whether the conflict is insubstantial or whether it is in the best interest of the ward for the conservator to continue to serve and not forfeit any property right. If the court finds that the conflict of interest is substantial or contrary to the best interest of the ward, the conservator may either resign or forfeit the property interest that is the source of the conflict.

“We review a probate court’s evidentiary holdings under the familiar abuse of

discretion standard of review.” (Citations and footnote omitted.) Dorsey v. Kennedy,

284 Ga. 464 (1) (668 SE2d 649) (2008). But because a transcript is necessary for a

review of the evidence presented at the hearing on this matter, and the record here

does not contain a transcript, we “must presume the evidence was as the probate court

found and its judgment correct on all issues presented. [Cit.]” Gordon v. Cotton, 285

Ga. 826, 827 (684 SE2d 621) (2009). We therefore affirm the probate court’s ruling

with regard to the conservator’s alleged conflict of interest.

2. Attorney fees.

4 The Ward complains that the probate court erred in setting an hourly rate at

which her hired counsel could bill for his services.4 We vacate and remand for the

probate court to consider parol evidence on this issue. But first we address whether

the fee agreement contemplated a flat fee or an hourly rate, an issue raised by the

dissent.

(a) The parties contemplated an hourly rate.

The dissent argues that application of the rules of contract construction leads

to the conclusion that the Ward and her attorney intended a flat rate when they

entered into the Fee Agreement and Contract for Representation. But the parties do

not challenge on appeal the probate court’s ruling that the fee agreement “expressly

contemplate[s] an hourly rate for services.” Nonetheless, given our de novo standard

of review, see Reichman v. Southern Ear, Nose & Throat Surgeons, 266 Ga. App.

696, 699 (1) (598 SE2d 12) (2004), and the dissent’s discussion of the issue, we

address whether the fee agreement provided for a flat fee or an hourly rate.

The Fee Agreement and Contract for Representation provides in pertinent part:

Fee

4 While this enumeration concerns the Ward’s counsel’s fees, it indirectly relates to the conservatorship. As noted by the probate court, “the conservator . . . needs direction in how to assess and pay” the fees charged by the Ward’s counsel.

5 The Client agrees to pay the Firm a retainer of $2,700.00 to try and cover the case through its completion.

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Related

Dorsey v. Kennedy
668 S.E.2d 649 (Supreme Court of Georgia, 2008)
Reichman v. Southern Ear, Nose & Throat Surgeons, P.C.
598 S.E.2d 12 (Court of Appeals of Georgia, 2004)
Lewis v. Uselton
416 S.E.2d 94 (Court of Appeals of Georgia, 1992)
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Schwartz v. Schwartz
561 S.E.2d 96 (Supreme Court of Georgia, 2002)
Gordon v. Cotton
684 S.E.2d 621 (Supreme Court of Georgia, 2009)
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Estate of Pitts v. City of Atlanta
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In Re: Estate of Lorraine McKitrick, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-lorraine-mckitrick-gactapp-2014.