In Re Thomas

CourtVermont Superior Court
DecidedMarch 27, 2025
Docket23-cv-4886
StatusPublished

This text of In Re Thomas (In Re Thomas) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Thomas, (Vt. Ct. App. 2025).

Opinion

SUPERIOR COURT CIVIL DIVISION Washington Unit Case No. 23-CV-04886 65 State Street Montpelier VT 05602 802-828-2091 www.vermontjudiciary.org

In re: Miriam Thomas

Opinion and Order on Motion to Dismiss

This is an appeal from probate division, No. 333-5-18 Wnpr. On October 2,

2023, the probate division issued a “Consolidated Final Judgment” against former

financial guardian Paul Thomas. In that case, it awarded the Estate of Miriam

Thomas (“Estate”) a reimbursement of $1,013,981, and awarded attorney’s fees to

the Estate, as well as costs to Bruce Thomas and Elizabeth Thomas, beneficiaries of

the Estate. Paul1 appealed that order, and has moved to dismiss for lack of

jurisdiction, lack of standing, and failure to state a claim upon which relief can be

granted. The Estate opposed the dismissal, and the Court heard oral arguments on

the motion. The Court makes the following determinations.

Background

Paul was appointed Miriam’s financial guardian in 2010. In 2016, Bruce and

Elizabeth filed motions to remove Paul under 14 V.S.A. § 3077 and Vt. R. Prob. P.

67. In March 2018, the Probate Division concluded that Paul had breached his

duties as guardian and ordered him to be replaced within 30 days of the order. The

1 For ease of reference and clarity, the Court will employ the first names of the

various persons bearing the Thomas surname. 1 order also instructed Paul to submit a final accounting and supporting

documentation, and also prohibited Paul from using Miriam’s resources without

prior approval of the court. The court stated that it would schedule an evidentiary

hearing to determine Paul’s liability, if any, for his deficiencies as guardian. See In

re Guardianship of Miriam H. Thomas, No. OeP184-09 GI, slip op. at 4–10 (Vt.

Super. Ct. Mar. 21, 2018) (Lewis, J.). The court appointed Stephen Ankuda as

successor guardian later in 2018. Id. After Miriam died in April 2019, the court

appointed Ankuda as the administrator of the Estate. At some point, the Estate

was substituted as a party. The record does not clearly show that any objection was

lodged to the substitution.

In 2020, the probate division conducted evidentiary hearings to determine

Paul’s potential liability to the estate. On January 25, 2021, the probate division

issued an order recounting the deficiencies it referenced in its March 2018 order. In

re: Thomas, No 333-5-18 Wnpr, slip op at 1–4 (Vt. Super. Ct. Jan. 25, 2021) (Kilgore,

J.). The probate division made new factual findings about each deficiency, then

concluded that Paul did not meet his burden or showing that his actions as a

fiduciary were reasonable “whether by clear and convincing evidence or a lesser

standard.” Id., ¶ 105. The court noted that, while the accounts for 2010, 2011, and

2012 had been allowed, it found no record that accounts after 2012 had ever been

approved. Id., ¶ 108. The court concluded that Paul’s fees as guardian were neither

reasonable nor supported by documentary evidence, and that his self-dealing was

not made in good faith or on fair terms. Id., ¶¶ 112 and 117.

2 The probate division went on to apply 14 V.S.A. § 917 and the Restatement of

the Law—Trusts § 100 & §100, cmt a (3d) to make conclusions about the “damages”

caused by Paul’s breaches of duty and waste. Id., ¶¶ 126–130; 130–143; 145. The

court summarized the grounds for Paul’s liability as: filing documents “late or not

at all,” disobeying court orders, overcharging the estate, engaging in self-dealing

and conflict of interest, failing to maintain adequate records, and misrepresenting

the financial status of the ward’s estate to the court. Id., ¶ 144. The court tabulated

the amount that Paul was ordered to return to the estate to “make whole the ward

or in this case the ward’s estate” at $1,013,981. Id., ¶ 145. Further, the probate

division ordered Paul to reimburse the Estate for attorney’s fees to be determined

later. Id., ¶¶ 147-149.

Paul appealed to this court, which dismissed the matter and vacated the

January 25, 2021 probate order, concluding that the probate division lacked subject-

matter jurisdiction to order compensatory damages in that context. Thomas v.

Thomas, No. 21-CV-00602, slip op. at 3–6 (Vt. Super Ct. Feb. 4, 2022) (Mello, J.).

The civil division reasoned that neither 14 V.S.A. § 3077 nor Vt. R. Prob. P. 67, nor

any statute controlling guardians, gives probate division “the authority to evaluate

damage claims against guardians.” Id. at 2. The court determined that Vt. R. Prob.

P. 67 was intended “to serve coercive or punitive purposes while a person is still a

fiduciary,” i.e., before removal. Id. at 3. The court also examined the question of

whether 14 V.S.A. § 917 applied in this situation, and concluded that like Vt. R.

Prob. P. 67, section 917 was intended to empower the probate division to regulate a

3 guardian’s conduct, and could no longer serve that purpose after Paul had been

removed as guardian and the ward had died. Id. at 4. An appeal followed.

The Vermont Supreme Court determined that the civil division lacked

subject-matter jurisdiction to hear the appeal because the probate division’s order

had not yet determined the attorney’s fee award and, thus, was not a final order

subject to appeal. In re Est. of Thomas, 2022 VT 59, ¶ 15, 217 Vt. 368, 373–74. It

remanded the case to the probate court.

On remand, the probate division issued a Decision on Motions to Dismiss and

Motion for Attorney’s Fees and Costs, in which it concluded that “[a]n ancillary and

incidental power necessary to enforce Paul Thomas’ statutory obligations is to place

a value on the breach of that duty.” In re: Thomas, 333-5-18 Wnpr, slip op. at 2 (Vt.

Super. Ct. Oct 2, 2023) (Kilgore, J.). Further, the probate division determined that

14 V.S.A. § 917 includes not only regulation of estate administrators, but also

applies to guardians, giving the probate division the authority to order a guardian

to pay attorney fees and “losses incurred because of an act or omission.” Id. at 7

(quoting 14 V.S.A. § 917).

In a Consolidated Final Judgment, the probate division referred to the

“damages” that it had determined in the January 25, 2021 “Losses Order” and

added them to its determination of attorney’s fees and costs. In re: Thomas, 333-5-

18 Wnpr, slip op. at 1–2 (Vt. Super. Ct. Oct. 2, 2023) (Kilgore, J.). It clarified,

however, that it had not determined tort claims or awarded damages but, instead,

had determined the sums necessary to make the Estate whole based on the final

4 accounting. It also noted that the Consolidated Final Judgment did “not discharge

Paul Thomas as former guardian of the Ward,” and that, following its entry, “the

Ward’s representative may prosecute the bond pursuant to the procedures

contained in 14 V.S.A. § 2108.” Id. at 2. Paul now appeals the October 2, 2023

Consolidated Final Judgment.

Discussion

Paul makes three primary arguments in support of dismissal: lack of subject-

matter jurisdiction, lack of standing, and lack of proper notice. The parties do not

disagree as to the legal standards that the Court should employ to analyze the

motions. The Court will discuss each point in turn.

I. Jurisdiction

Paul asserts that the probate division does not have subject-matter

jurisdiction to award damages under the Vt. R. Prob. P. 67, 14 V.S.A.

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Related

Manley v. Brattleboro Trust Co.
78 A.2d 488 (Supreme Court of Vermont, 1951)
In Re: Will of Prudenzano
68 A.2d 704 (Supreme Court of Vermont, 1949)
Estate of Emil Kuhling by Richard W. Kuhling v. Taylor Glaze
2018 VT 75 (Supreme Court of Vermont, 2018)
Hendee v. Cleaveland
54 Vt. 142 (Supreme Court of Vermont, 1881)
In re Estate of Piche
697 A.2d 674 (Supreme Court of Vermont, 1997)
In Re Estate of Miriam Thomas (Stephen Ankuda, Administrator)
2022 VT 59 (Supreme Court of Vermont, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
In Re Thomas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-thomas-vtsuperct-2025.