In re Estate of Reuben E. Waugh, Jr. Gregory Waugh

123 A.3d 958, 2015 D.C. App. LEXIS 435, 2015 WL 5062258
CourtDistrict of Columbia Court of Appeals
DecidedAugust 27, 2015
Docket14-PR-635
StatusPublished
Cited by1 cases

This text of 123 A.3d 958 (In re Estate of Reuben E. Waugh, Jr. Gregory Waugh) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals 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 Reuben E. Waugh, Jr. Gregory Waugh, 123 A.3d 958, 2015 D.C. App. LEXIS 435, 2015 WL 5062258 (D.C. 2015).

Opinion

BLACKBURNE-RIGSBY, Associate Judge:

Over the course of supervised probate, and in two prior appeals before this court, appellant Gregory Waugh has raised multiple challenges to the administration and distribution of the estate of his father, decedent Reuben E. Waugh, who died intestate. Appellant’s primary claim in the present appeal relates to compensation paid to appellee-attorney Paul M. Toulouse, who has served in three capacities— as attorney for the estate, as co-personal representative with appellee Shanese L. Barber, the decedent’s common law wife, and as the lawyer for Ms. Barber in her efforts to establish that she is an heir of the estate. Appellant contends that the trial court erroneously denied his challenges to Mr. Toulouse’s compensation because appellant raised them by way of an objection to the co-personal representatives’ account of estate administration, rather than by a separate petition under D.C.Code § 20-753 (2001). On appeal, we address a question of statutory construction: whether our probate statute permits an interested party to petition the court for a review of the reasonableness of compensation paid from estate funds by way of an objection to the personal representative’s account of estate administration, rather than by a separate petition. We answer in the affirmative and remand for proceedings consistent with this holding. 1

I. Factual Background

Reuben E. Waugh, Jr., died intestate on July 17, 2008, leaving Ms. Barber and appellant as potential heirs. Both potential heirs filed petitions for probate, but the trial court granted Ms. Barber’s petition after an evidentiary hearing in which it determined that Ms. Barber was the decedent’s common law wife. The trial court also appointed Ms. Barber as co-personal representative of the estate with her attorney, Mr. Toulouse, who also served as the attorney for the estate.

A. Appellant’s ftrst and second appeals

In appellant’s first appeal before this court, he challenged the trial court’s determination that Ms. Barber was the decedent’s common law wife, and we affirmed. See In re Estate of Reuben E. Waugh, Jr.; Gregory Waugh, Appellant, No. 09-PR-1038, Mem. Op. & J. (D.C. October 19, 2010). Mr. Toulouse represented Ms. Barber in that appeal and received compensation from estate funds.

During and after the first appeal, Ms. Barber and Mr. Toulouse continued to administer the estate in accordance with their duties as co-personal representatives. Pursuant to D.C.Code § 20-721 (2001), 2 *961 they submitted two accounts of the management and distribution of the estate to appellant and to the probate division for approval, the first on July 19, 2010 (“First Account”), and the second and final on April 29, 2011 (“Final Account”). Mr. Toulouse also provided appellant with a proposal to distribute the estate’s assets in kind, pursuant to D.C.Code § 20-1102(d), 3 on March 25, 2011. In this proposal, Mr. Toulouse requested that appellant raise any objections to the distribution in kind within thirty days, though appellant did not meet this deadline.

Appellant’s only responses to the co-personal representatives’ communications came in the form of objections to the First and Final Accounts, filed pursuant to D.C.Code § 20-726 (2001). 4 Appellant filed objections to the First Account on April 24, 2010, asserting, among other things, that Mr. Toulouse had abdicated his responsibility as co-personal representative by failing to require supporting documentation for the attorney’s fees paid to him for his services, and abdicated his responsibility as attorney for the estate by failing to provide such documentation. Appellant filed objections to the Final Account on June 1, 2011, renewing his objections to the First Account and, for the first time, objecting to Mr. Toulouse’s proposal for distribution of the estate in kind as “unfair and uneven.” At the time of this filing, more than two months had elapsed since appellant received this proposal, and thus appellant had missed the thirty-day window in which to object to the proposed distribution, pursuant to D.C.Code § 20-1102(d). 5 The trial court denied appellant’s objections to both accounts without making specific findings, and appellant once again appealed to this court. 6

In appellant’s second appeal, he challenged the trial court’s denial of his objections to the First Account and the Final Account, arguing error on the merits. Mr. Toulouse and Ms. Barber countered on procedural grounds, arguing that appellant had failed to file a petition challenging the reasonableness of compensation paid from the estate under D.C.Code § 20-753(a) 7 *962 and that his objection to the distribution of estate assets . was untimely under D.C.Code § 20-1102(d). 8 See In re Estate of Reuben E. Waugh, Jr.; Gregory Waugh, Appellant, No. 11-PR-1427, Mem. Op. & J., 60 A.3d 455 (D.C. January 14, 2013). We concluded that the record was insufficient to assess the merits of either party’s assertions and remanded for the trial court to “further explain its rulings” and make the following inquiries:

First, were the objections appellant Waugh filed to the first and second accounts sufficient to challenge the attorney’s fees paid to appellee Toulouse for his legal work to establish and defend appellee Barber’s status.as an heir of the estate, or was appellant required to follow a different procedure?
Second, assuming appellant’s objections were .sufficiently preserved, should the estate be required to pay Toulouse’s attorney’s fees for: services provided to Ms. Barber to establish her status as the decedent’s common law wife; services provided to Ms. Barber defending the ruling on appeal; and/or any other services provided to Ms. Barber in her capacity as heir, or putative heir, as distinguished from her capacity as co-personal representative?
Third, to the extent appellant seeks a different distribution of assets, is his claim barred by D.C.Code § 20-1102

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Bluebook (online)
123 A.3d 958, 2015 D.C. App. LEXIS 435, 2015 WL 5062258, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-reuben-e-waugh-jr-gregory-waugh-dc-2015.