In re Estate of Piton

2024 IL App (3d) 240051, 255 N.E.3d 1005
CourtAppellate Court of Illinois
DecidedNovember 12, 2024
Docket3-24-0051
StatusPublished

This text of 2024 IL App (3d) 240051 (In re Estate of Piton) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois 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 Piton, 2024 IL App (3d) 240051, 255 N.E.3d 1005 (Ill. Ct. App. 2024).

Opinion

2024 IL App (3d) 240051

Opinion filed November 12, 2024 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

In re ESTATE OF PATRICK E. PITON, ) Appeal from the Circuit Court ) of the 18th Judicial Circuit, Deceased ) Du Page County, Illinois. ) (Larisa A. Piton, Lawrence Piton, and Alexei ) Piton, ) ) Appeal No. 3-24-0051 Petitioners-Appellants, ) Circuit Nos. 22-PR-499 ) v. ) ) Dorothy Sprenger, ) The Honorable ) Paul M. Fullerton, Respondent-Appellee). ) Judge, Presiding. ____________________________________________________________________________

JUSTICE HETTEL delivered the judgment of the court, with opinion. Justice Peterson concurred in the judgment and opinion. Justice Albrecht dissented, with opinion. ____________________________________________________________________________

OPINION

¶1 Petitioners Larisa Piton, Lawrence Piton, and Alexei Piton are a niece and nephews of the

decedent, Patrick E. Piton. Respondent Dorothy Sprenger is Patrick’s sole surviving sibling. Prior

to his death, Patrick signed a power of attorney authorizing Dorothy to act as his agent with respect

to his Vanguard accounts. Petitioners filed a claim for breach of fiduciary duty against Dorothy,

alleging that she failed to name them as beneficiaries of Patrick’s Vanguard nonretirement accounts, as Patrick instructed her to do. Dorothy filed a motion to dismiss petitioners’ claim with

prejudice, asserting that petitioners lack standing. The circuit court granted Dorothy’s motion.

Petitioners appeal, arguing that the circuit court erred in dismissing their claim for lack of standing.

We affirm.

¶2 I. BACKGROUND

¶3 Patrick E. Piton died on March 28, 2022. He had no children and no surviving spouse. His

parents and one sibling, V. Lawrence Piton, predeceased him. One sibling, Dorothy Sprenger,

survived him. During his lifetime, Patrick owned several Vanguard retirement accounts,

nonretirement accounts, and a joint tenancy account with Dorothy. At the time of his death, Patrick

had more than $1 million in his Vanguard retirement accounts and more than $3 million in his

Vanguard nonretirement accounts.

¶4 During his life, Patrick named “Transfer on Death (TOD) Plan beneficiaries” for his

Vanguard accounts. Prior to 2017, Patrick named Dorothy as the sole beneficiary of all his

Vanguard accounts. Then, in 2017, Patrick designated Dorothy and V. Lawrence each as 50%

beneficiaries of his Vanguard retirement accounts. At that time, V. Lawrence was named Patrick’s

agent in a healthcare power of attorney, with Dorothy named as successor agent.

¶5 On April 1, 2018, V. Lawrence died, and Dorothy became Patrick’s healthcare agent. In

early 2019, Patrick’s health began to deteriorate. In June 2019, Patrick signed a power of attorney

giving Dorothy “Full Agent Authorization” over his Vanguard accounts, which allowed her to

change the beneficiaries of the accounts. In December 2020, Dorothy removed V. Lawrence as a

beneficiary of the Vanguard retirement accounts and designated herself as the sole beneficiary of

those accounts. Thereafter, Dorothy designated her children as contingent beneficiaries on the

Vanguard accounts.

2 ¶6 In June 2022, petitioners Larisa A. Piton, Lawrence Piton, Alexei Piton, and Lucille A.

Moll, 1 V. Lawrence’s children and Patrick’s nieces and nephews, filed a complaint against

Dorothy alleging undue influence and fraud in chancery court in Du Page County case No. 22-

CH-131. That case was assigned to Judge Bonnie Wheaton.

¶7 On June 17, 2022, Dorothy filed a petition in probate court to probate Patrick’s estate in

Du Page County case No. 22-PR-499. According to Dorothy, Patrick’s estate had a value of

approximately $37,000. Dorothy attached to the petition a copy of Patrick’s will, dated January 8,

1968, which provided in pertinent part:

“I give, devise and bequeath all the rest, residue, and remainder of my estate, whether

real, personal or mixed which I may own or possess at the time of my death or to which I

may then be entitled and wheresoever the same may be situated to my beloved parents,

ANN M. PITON and VICTOR E. PITON, share and share alike; provided, however that if

neither survive me, then to my sister, DOROTHY A. SPRENGER and my brother, V.

LAWRENCE PITON, share and share alike; provided however, that if neither my sister or

brother survive me, then to my nephews and nieces in equal shares.”

On July 6, 2022, Judge Paul Fullerton appointed Dorothy as independent administrator of Patrick’s

estate.

¶8 A. Case No. 22-PR-499

¶9 In January 2023, petitioners, along with their mother (also named Larisa Piton), filed a

petition to contest Patrick’s will in case No. 22-PR-499, alleging a will contest (count I), and an

action for construction of Patrick’s 1968 will (count II). Dorothy filed a motion to dismiss the

petition, asserting that (1) petitioners failed to present evidence of the existence of a codicil or

1 Moll later voluntarily withdrew her appearance as a petitioner.

3 other document drafted by Patrick after 1968 and (2) the terms of the will ambiguously provide a

per capita distribution of assets to her as Patrick’s sole surviving sibling. On April 28, 2023, Judge

Fullerton granted Dorothy’s motion to dismiss the petition, dismissing count II with prejudice and

count I without prejudice.

¶ 10 In May 2023, petitioners filed a petition for relief, alleging breach of fiduciary duty by

Dorothy (count I), and seeking an accounting of Patrick’s Vanguard accounts (count II). In count

I, petitioners alleged that in 2019 and 2020 Patrick directed Dorothy to add petitioners as

beneficiaries to his Vanguard nonretirement accounts but that Dorothy never did so.

¶ 11 In June 2023, Dorothy filed a motion to dismiss the petition with prejudice, asserting that

petitioners lack standing to bring a breach of fiduciary duty claim.

¶ 12 B. Case No. 22-CH-131

¶ 13 On January 3, 2023, petitioners filed their first amended complaint against Dorothy in case

No. 22-CH-131, alleging breach of fiduciary duty (count I), tortious interference with inheritance

expectancy (count II), undue influence (count III), and fraud (count IV). Dorothy filed a motion to

dismiss petitioners’ amended complaint, asserting that petitioners lack standing to seek damages

from her alleged breach of fiduciary duty and failed to state a claim for tortious interference with

an inheritance expectancy, undue influence and fraud. On April 12, 2023, Judge Wheaton entered

an order granting Dorothy’s motion to dismiss, dismissing counts II through IV without prejudice

for failure to state a claim. With respect to count I, Judge Wheaton stated: “To the extent Count I

pleads a direct cause of action by Plaintiffs against Defendant, Count I is dismissed with prejudice

***. To the extent count I pleads an action on behalf of Patrick Piton’s Estate, Count I is dismissed

without prejudice, but if repled, must be filed in Case No. 22 PR 499, the Estate of Patrick E.

Piton.”

4 ¶ 14 In May 2023, petitioners filed a second amended complaint in case No. 22-CH-131,

alleging tortious interference with inheritance expectancy.

¶ 15 C. Consolidation of Cases

¶ 16 In June 2023, petitioners filed a motion to consolidate case Nos. 22-PR-499 and 22-CH

131. Dorothy opposed the motion. On September 28, 2023, Judge Fullerton entered an order

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2024 IL App (3d) 240051, 255 N.E.3d 1005, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-piton-illappct-2024.