In Re Testamentary Trust of Flynn, Unpublished Decision (8-5-2005)

2005 Ohio 4028
CourtOhio Court of Appeals
DecidedAugust 5, 2005
DocketNos. 20699, 20700.
StatusUnpublished

This text of 2005 Ohio 4028 (In Re Testamentary Trust of Flynn, Unpublished Decision (8-5-2005)) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law.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In Re Testamentary Trust of Flynn, Unpublished Decision (8-5-2005), 2005 Ohio 4028 (Ohio Ct. App. 2005).

Opinion

OPINION
{¶ 1} This matter comes before us on two consolidated appeals brought by Georgianna Parisi as trustee for the testamentary trust of Jennifer Flynn.

{¶ 2} In Montgomery App. No. 20700, Parisi appeals from the trial court's decision and entry allowing beneficiary Jennifer Flynn to disclaim any interest in the foregoing trust and ordering the trust terminated with the corpus going to remainderperson Vickie Flynn. In Montgomery App. No. 20699, Parisi appeals from the trial court's subsequent decision and entry ruling on her applications for attorney fees, trustee fees, and costs for her work on the trust. The appellees in both cases are Jennifer Flynn and her mother, Vickie Flynn. In an earlier ruling, we consolidated the two appeals because they involve the same probate case.1

{¶ 3} Parisi advances two assignments of error in the consolidated appeals. First, she contends the trial court erred in ordering the Jennifer Flynn trust terminated. In support, she argues (1) that Jennifer Flynn was too young to disclaim her interest in the trust and (2) that the trial court could not terminate the trust absent a motion from the trustee. Second, she claims the trial court erred in applying a 1955 probate case from Cuyahoga County to assess the reasonableness of her attorney fee request. Parisi insists that Mont. Co. Probate Rule 71.1 obligated the trial court to assess the reasonableness of her attorney fee request under standards found in the Code of Professional Responsibility.

{¶ 4} Based on the reasoning set forth below, we find that Jennifer Flynn was old enough to disclaim her interest in the trust. We also conclude that the absence of a motion by the trustee did not preclude the trial court from terminating the trust. We do agree, however, that the applicable standards for judging the reasonableness of an attorney fee request are found in the Code of Professional Responsibility. Although the trial court cited a 1955 probate court case from Cuyahoga County, we believe its analysis adequately encompassed the relevant considerations found in the Code of Professional Responsibility. Moreover, we conclude that the trial court's fee award was not an abuse of discretion. As a result, Parisi's assignments of error will be overruled, and the trial court's judgment will be affirmed.

I. Background
{¶ 5} On March 31, 1993, an individual named Benny Jones executed a will that had been drafted by Parisi. Therein, Jones established three testamentary trusts and named Parisi as trustee of each one. Two of the trusts were created to assist his grandchildren, Jennifer Flynn and Nicholas Flynn, with college expenses. Each educational trust was to terminate on the grandchild's twenty-fifth birthday, with any remaining funds to be distributed to Vickie Flynn, who is one of Jones' four daughters and the mother of Jennifer and Nicholas. The third trust was created to provide for Jones' "close friend and companion" Sharon Roe. It is the subject of the related appeal mentioned, supra, in footnote one.

{¶ 6} Benny Jones died on May 26, 1993. Thereafter, litigation arose when remainderperson Vickie Flynn on several occasions filed exceptions to Parisi's periodic accountings of the trust funds. Vickie Flynn also unsuccessfully moved to have Parisi removed as trustee for incompetence.

{¶ 7} In June 2003, Jennifer Flynn executed and filed a disclaimer of her interest in the educational trust established for her benefit. Jennifer Flynn was then eighteen years old. In light of the disclaimer, remainderperson Vickie Flynn also moved to have the Jennifer Flynn trust terminated. Parisi opposed the disclaimer, however, arguing that Ohio law precludes individuals younger than twenty-one years of age from disclaiming an interest in a trust. Parisi also argued that the trial court could not terminate the trust without a motion from the trustee requesting the same.

{¶ 8} To facilitate a possible settlement, on June 14, 2004, Vickie Flynn waived her exceptions to the periodic accountings that Parisi had filed for the three trusts. Two days later, the trial court held a hearing on the disclaimer and termination issue with regard to the Jennifer Flynn trust, as well as on applications for attorney fees, trustee fees, and costs that Parisi had filed for her work on each of the three trusts.

{¶ 9} In a subsequent August 13, 2004, decision and entry, the trial court read R.C. § 1339.68 as providing for individuals younger than eighteen years of age to disclaim an interest in a trust through a guardian. The trial court also read the statute as requiring an individual to be at least twenty-one years of age to disclaim an interest in a trust on her own. The trial court then determined that the statute made no provision for disclaimers by individuals who were eighteen, nineteen, or twenty years old. The trial court attributed this "gap" to a legislative "oversight" and concluded that it constituted "age discrimination without basis in the law." As a result, the trial court held that Jennifer Flynn could disclaim her interest in the trust, despite its belief that the statute did not authorize such action. The trial court then turned to R.C. § 2109.62, which provides for the termination of a trust upon a motion by the trustee and the satisfaction of certain conditions. Although it acknowledged that the trustee had not moved to have the Jennifer Flynn trust terminated, the trial court found all of the other conditions satisfied. The trial court then construed Parisi's purported "acquiescence" to Vickie Flynn's motion to terminate the trust as being tantamount to a motion by the trustee herself. As a result, the trial court ordered the Jennifer Flynn trust terminated and the trust corpus distributed to remainderperson Vickie Flynn.

{¶ 10} On the issue of attorney fees, trustee fees, and costs in connection with the Jennifer Flynn trust, Parisi requested "attorney/trustee fees" totaling $14,805.00 and costs of $2,707.44. In an August 20, 2004, decision and entry, however, the trial court awarded her attorney fees of $2,800, trustee fees of $2,494.83, and costs of $186.68.2 The trial court also noted that Parisi previously had received an additional $980.36 for "costs and fees." In support of its decision, the trial court relied on standards contained in In re Estate of Haggerty (1955), 70 Ohio Law Abs. 463, 128 N.E.2d 680, a Cuyahoga County probate court case, to assess the reasonableness of Parisi's "attorney/trustee fee" request. This timely appeal followed.

II. Analysis
{¶ 11} In her first assignment of error, Parisi contends the trial court erred in ordering the Jennifer Flynn trust terminated. In support, she argues (1) that Jennifer Flynn was too young to disclaim her interest in the trust and (2) that the trial court could not terminate the trust absent a motion from the trustee.

{¶ 12} On the former issue, Parisi insists that R.C. §1339.68 requires a beneficiary to be twenty-one years of age to disclaim an interest in a trust. We disagree. The statute defines a "disclaimant" as including "any person" who is a beneficiary under a testamentary instrument or who is entitled to take an interest in real or personal property upon the death of another. R.C.

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Related

Ohio National Bank v. Adair
374 N.E.2d 415 (Ohio Supreme Court, 1978)
Joyce v. General Motors Corp.
551 N.E.2d 172 (Ohio Supreme Court, 1990)
In re Estate of Haggerty
70 Ohio Law. Abs. 463 (Cuyahoga County Probate Court, 1953)

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Bluebook (online)
2005 Ohio 4028, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-testamentary-trust-of-flynn-unpublished-decision-8-5-2005-ohioctapp-2005.