In Re The Estate Of Sharon Marie O'hara

CourtCourt of Appeals of Washington
DecidedMay 29, 2024
Docket57421-7
StatusUnpublished

This text of In Re The Estate Of Sharon Marie O'hara (In Re The Estate Of Sharon Marie O'hara) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re The Estate Of Sharon Marie O'hara, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

May 29, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Estate of: No. 57421-7-II

SHARON MARIE O’HARA, UNPUBLISHED OPINION

Deceased.

KRISTINA C. UDALL, as Administrator of the ESTATE OF SHARON MARIE O’HARA,

Respondent,

v.

FELECIA J. O’HARA, as Administrator of the ESTATE OF CHARLES W. O’HARA,

Appellant.

CHE, J. ⎯ The Estate of Charles O’Hara appeals the trial court orders determining that

Charles breached his fiduciary duties, determining that the Estate of Sharon O’Hara had a

community property interest in Charles’s retirement funds after Sharon’s death, crediting that

interest to the Estate of Sharon, and awarding the Estate of Sharon damages calculated using a

prejudgment interest rate of 12 percent. No. 57421-7-II

Sharon and Charles O’Hara were married for almost 40 years. Sharon executed a new

will in 2017 revoking all prior wills and changing the residuary beneficiary from Charles to the

University of Washington, among other changes. Eventually, Charles probated Sharon’s earlier

1983 will, not the 2017 will, and he remarried. Charles failed to notify the court or other

interested parties about the 2017 will, and he did not maintain an inventory. Charles used the

Estate of Sharon’s assets for his own benefit for 16 months before he died. The Estate of Sharon

filed a creditor’s claim against the Estate of Charles for a breach of fiduciary duties. The Estate

of Sharon sought its community property interest in some of Charles’s retirement accounts, and

eventually, the Estate of Sharon filed a Trust and Estate Dispute Resolution Act (TEDRA),

chapter 11.96A RCW, petition.

We hold that (1) Sharon’s community property interest in the contested retirement funds

did not automatically revert to Charles after her death, (2) the trial court had subject matter

jurisdiction over the retirement funds, (3) the trial court did not err by crediting Sharon’s interest

in the retirement funds to her estate even though her will did not specifically reference that

interest, (4) Charles breached his fiduciary duties to the Estate of Sharon, and (5) the trial court

abused its discretion by awarding damages calculated using a prejudgment interest rate of 12

percent as there was no evidence about the rate of return the improperly withheld funds would

have yielded. We deny both parties attorney fees on appeal and affirm the grant of attorney fees

below.

We vacate the damages award and remand for the trial court to determine if damages

calculated using a prejudgment interest rate of 12 percent per annum is warranted based on the

evidence. We otherwise affirm.

2 No. 57421-7-II

FACTS

Sharon and Charles O’Hara married in 1978. Sharon executed a will in 1983 devising

her residuary estate to Charles. In 2016, Sharon executed a new will in 2017. The 2017 will

revoked all prior wills. The 2017 will devised Sharon’s entire estate, less two specific bequests

to charitable organizations, via a residuary clause “to the University of Washington for medical

research in COPD and scholarships for women in the medical field.” Clerk’s Papers (CP) at 266.

The estate planning attorney retained the 2017 will after Sharon executed it.

Sharon died on June 7, 2017. Charles was appointed as the personal representative under

the 2017 will. Charles married Felecia O’Hara just days after being appointed as the personal

representative for the Estate of Sharon.

The estate planning attorney gave Charles the original 2017 will with instructions about

the time period for probating the will. But Charles did not probate the 2017 will as directed, and

the original 2017 will has never been found. And Charles did not notify the court or Sharon’s

beneficiaries about the 2017 will.

About a year after Sharon’s death, Charles probated Sharon’s 1983 will, not the 2017

will, in Jefferson County. Charles did not maintain an inventory or keep accounting records for

the Estate of Sharon. Instead of properly administering the estate under Sharon’s 2017 will,

Charles used the assets of the Estate of Sharon for his own benefit for 16 months.

In December 2017, Charles claimed a Kitsap Credit Union account with a date of death

value of $30,161.33. The Kitsap Credit Union account was established in 1996 and was titled in

Sharon’s name. The Estate of Sharon had a community property interest of $15,080.66 in the

account. Charles submitted a small estate affidavit to claim this account by asserting that the net

3 No. 57421-7-II

probate estate did not exceed $100,000 and that he was entitled to full payment of the Kitsap

Credit Union account.1

Towards the beginning of 2018, Charles cashed out or converted a Fidelity IRA in his

name valued at $245,427.97 as of June 1, 2017, which the Estate of Sharon later claimed a

community property interest in. Charles also cashed out or converted a USAA Annuity titled in

his name valued at $360,087.32 as of January 1, 2018, which the Estate of Sharon later claimed a

community property interest in.2 Charles indirectly invested some of the proceeds from the IRA

conversions into several distressed rental properties in Florida.

Charles died in October 2018. Felecia was appointed as the personal representative of his

estate. After Charles’s death, Sharon’s grandson probated a copy of Sharon’s 2017 will in

1 Charles also claimed a Kitsap bank account with $220.04. The Estate of Sharon had a $110.02 community property interest in the account. Additionally, Felecia, Charles’s wife at that time, claimed Sharon and Charles’ entire joint federal tax refund from 2015. The Estate of Sharon has a $1,400 community property interest in that tax refund. 2 The trial court made the following findings relating to Charles’s IRAs:

C. On or about January 22, 2018, Charles cashed out or converted the Fidelity IRA . . . titled in his name, in which Sharon had a community property interest as a nonparticipating spouse. RCW 6.15.020(6). He moved these funds into a rollover IRA with Charles Schwab. The Fidelity IRA was valued at $245,427.97 as of June 1, 2017, and as such, Sharon’s community property interest in that asset as of her date of death was an estimated $122,713.99.

D. On or about February 5, 2018, Charles cashed out or converted the USAA Annuity . . . titled in his name, in which Sharon had a community property interest, into a rollover IRA with Charles Schwab. The USAA annuity was valued at $360,087.32 (as of January 1, 2018, which is the closest value to the date of Sharon’s death that USAA would provide short of subpoena). Sharon’s estimated community property interest in that asset was $180,043.66.

CP at 267.

4 No. 57421-7-II

Kitsap County. Unaware of the probate proceeding in Jefferson County, the trial court appointed

him as the personal representative. Later, the parties agreed to cancel the Kitsap probate

proceeding.

The University of Washington petitioned the Jefferson County trial court to admit the

2017 will and appoint Kristina Udall, an uninterested attorney, as the administrator of the Estate

of Sharon. The Jefferson County trial court appointed Udall as the administrator of the estate in

December 2018. The University of Washington expended $14,897.80 in attorney fees to

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