In Re The Aaron Stapp Living Trust: Troy Stapp v. Amy Stapp

CourtCourt of Appeals of Mississippi
DecidedMay 31, 2022
Docket2020-CA-01282-COA
StatusPublished

This text of In Re The Aaron Stapp Living Trust: Troy Stapp v. Amy Stapp (In Re The Aaron Stapp Living Trust: Troy Stapp v. Amy Stapp) is published on Counsel Stack Legal Research, covering Court of Appeals of Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re The Aaron Stapp Living Trust: Troy Stapp v. Amy Stapp, (Mich. Ct. App. 2022).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF MISSISSIPPI

NO. 2020-CA-01282-COA

IN RE THE AARON STAPP LIVING TRUST: APPELLANT TROY STAPP

v.

AMY STAPP APPELLEE

DATE OF JUDGMENT: 08/03/2020 TRIAL JUDGE: HON. MITCHELL M. LUNDY JR. COURT FROM WHICH APPEALED: PANOLA COUNTY CHANCERY COURT, FIRST JUDICIAL DISTRICT ATTORNEY FOR APPELLANT: TAYLOR D. BUNTIN III ATTORNEYS FOR APPELLEE: A. E. (RUSTY) HARLOW JR. KATHI CRESTMAN WILSON MORGAN KAY JACKSON NATURE OF THE CASE: CIVIL - WILLS, TRUSTS, AND ESTATES DISPOSITION: AFFIRMED - 05/31/2022 MOTION FOR REHEARING FILED: MANDATE ISSUED:

BEFORE CARLTON, P.J., McDONALD AND EMFINGER, JJ.

EMFINGER, J., FOR THE COURT:

¶1. Aaron Stapp operated a successful cattle farm in Panola County for several years. On

December 17, 2009, he and his wife, Bobbie Stapp, created the Stapp Revocable Living Trust

and placed certain assets into the trust. On May 28, 2015, Aaron Stapp then created the

Aaron Stapp Living Trust and, again, placed certain assets into this trust.1 A quitclaim deed,

1 There were no trust documents admitted into evidence in this case. There is no inventory of assets for either trust and no annual reports for either trust. While there was some discussion during the trial that the trusts may have been merged, there is no evidence in the record of that fact. that was introduced into evidence at trial, indicated that the farmland at issue in this appeal

was first conveyed by Aaron T. Stapp and Bobbie N. Stapp to Aaron Stapp and Bobbie Stapp

as Trustees of the Stapp Revocable Living Trust on December 17, 2009. The farmland was

then conveyed by Aaron Stapp as Trustee of the Stapp Revocable Living Trust to Aaron

Stapp as Trustee of the Aaron Stapp Living Trust on May 28, 2015. It would appear that

Bobbie Stapp was deceased at the time of the latter conveyance, although there is no specific

reference to her death in the record on appeal.

¶2. Aaron Stapp died on October 21, 2016. His last will and testament was probated, and

his estate was opened on January 17, 2017, with Amy Stapp and Troy Stapp, his only

children and the parties here, serving as co-executors. Amy and Troy also became trustees

of both trusts at some point after their father’s death. The estate was closed on November

30, 2018. On July 10, 2019, Troy was removed as a trustee of the two trusts, leaving Amy

as the sole trustee. On September 27, 2019, Amy was removed as trustee, and attorney John

T. Lamar was appointed as trustee by the chancery court.2

2 The agreed order appointing Lamar as the trustee for “both trusts,” stated in part:

The Honorable John Lamar is hereby appointed as sole Trustee for both Trusts in this action. As it is the desire of both beneficiaries of the Trust to do so, the Trustee, in addition to any other duties and responsibilities, shall evaluate the propriety and potential for dissolving both Trusts pursuant to their terms.

(Emphasis added). Lamar was not a named party in this action, nor did he testify at trial. We have no record or other account of actions he may have taken as trustee. We have no evidence of Lamar’s opinion as to whether the continuance of the trust was necessary to achieve any material purpose of the trusts. See Miss. Code Ann. § 91-8-411(b) (Rev. 2018). That being said, Lamar was clearly aware of the litigation because his invoice for services rendered to the trusts was admitted into evidence at trial. Considering the direction he was

2 ¶3. On April 20, 2020, Amy filed a petition in the Chancery Court of Panola County,

Mississippi, asking the court to divide the corpus of the Aaron Stapp Living Trust or, in the

alternative, to make a distribution to the beneficiaries. The petition alleges that Amy and her

brother, Troy, are the only beneficiaries of the trust.3 Troy filed an answer and a counter-

petition on June 1, 2020. In his answer, Troy denied that the relief Amy requested should

be granted. In his counter-petition, Troy claimed that he should be reimbursed for certain

expenses he incurred on behalf of the trust and that Amy should be required to reimburse the

trust for her use of trust assets for her own benefit and for expenses the trust had incurred or

the income it had lost as a result of Amy’s use of trust assets. While Troy agreed that the

brokerage accounts should be divided after being adjusted as suggested in his counter-

petition, he argued that the farmland should not be sold, and should remain a trust asset.

given by the court in the order appointing him as trustee, it is significant to note that Lamar, as trustee, did not interpose any objection to the modification or termination of the trusts and did not notify the chancellor of any additional beneficiaries or interested parties. In fact, Lamar signed the chancery court’s final order distributing the assets to the two beneficiaries of the trust, Amy and Troy. 3 The dissent questions how the chancellor could determine who the beneficiaries of the trust were without having the trust documents. First, the parties agreed in the pleadings that they were the only beneficiaries of the trust. Second, we agree with the dissent that the trustee had a fiduciary duty to make the court aware of and protect the interest of any other beneficiary of the trust. However, as noted above, Lamar did not identify any other beneficiary. Third, the chancellor here is the same chancellor that presided over the probate of the estate of Aaron Stapp. The record is clear that the chancellor was familiar with the trust documents. In an agreed order from the estate file that was introduced as an exhibit, the chancellor quoted “Section 6.01 of the Living Trust.” That section ordered the distribution of a house in Cordova, Mississippi, to Amy Stapp and further provided, “If Amy Stapp is deceased, my Trustee shall distribute this property to Amy Stapp’s descendants, per stirpes.” This provision related to a specific asset and was not merely a general reference to the remainder of the trust assets. Obviously, Amy Stapp was not deceased, and there are no other beneficiaries of the trust other than Troy.

3 ¶4. These matters went to trial on June 24, 2020. Subsequently, the chancery court

entered an order on August 3, 2020, resolving the matters presented. On August 12, 2020,

Troy filed a “Motion to Amend and/or Clarify Judgment.” On August 13, 2020, Amy also

filed a “Motion to Clarify, Amend, and Reconsider.” After considering both motions, the

chancery court entered an additional order on October 28, 2020, which clarified that “all

liquid assets shall be divided between the two beneficiaries prior to the auction of the

remaining assets of the trust.” All the additional requests contained in Amy’s and Troy’s

motions were denied. The chancellor did not order that the farmland and houses be sold, and

they remain assets of the trust. Aggrieved by portions of the chancellor’s ruling, Troy

appeals.

STANDARD OF REVIEW

¶5. “This Court employs a limited standard of review on appeals from chancery court.”

In re Est. of Baumgardner, 82 So. 3d 592, 598 (¶15) (Miss. 2012).

[T]his Court “will not disturb the factual findings of a chancellor when supported by substantial evidence unless the chancellor abused his discretion, was manifestly wrong, [or his findings were clearly erroneous[,] or [he] applied an erroneous legal standard.”

Id. (quoting Biglane v.

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Bluebook (online)
In Re The Aaron Stapp Living Trust: Troy Stapp v. Amy Stapp, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-aaron-stapp-living-trust-troy-stapp-v-amy-stapp-missctapp-2022.