In re Woodmancy

7 Am. Tribal Law 361, 1 M.T.C.R. 75
CourtMohegan Trial Court
DecidedDecember 30, 2008
DocketNo. CV-08-0132
StatusPublished

This text of 7 Am. Tribal Law 361 (In re Woodmancy) is published on Counsel Stack Legal Research, covering Mohegan Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Woodmancy, 7 Am. Tribal Law 361, 1 M.T.C.R. 75 (Mo. 2008).

Opinion

MEMORANDUM OF DECISION

JANE W. FREEMAN, Judge.

The Petitioner, Kathleen Woodmancy (“Petitioner”), has petitioned the Court to authorize distributions from the grantor trust established by the Mohegan Tribe (“Tribe”) for her benefit. The Tribe contributes per capita benefits to grantor trusts for future distribution to minor Tribal members, in order to provide for their future safety and well being. MTC § 2-183(h). The Tribe has filed an Answer stating that it takes no position on the petition.

The Court has jurisdiction of the parties. The Petitioner is a member of the Tribe (Ex. 2) and the Tribe is a party to the proceeding. The petition has been filed under the provisions of the Gaming Revenue Allocation Plan, MTC § 2-181, et seq. (“GRAP”). Under the GRAP, the [363]*363Court may authorize the trustee or trustees of trusts established for minor children to make distributions to the parents or guardians of the trust beneficiaries, for the purposes and subject to the limitations set forth therein. MTC § 2-183(h)(5). This case differs from prior cases involving early distributions under the GRAP, in that the Petitioner is not the parent of the trust beneficiary but is the trust beneficiary herself. Therefore, the Court must address whether the Petitioner has standing to file this petition, since the question of standing implicates the Court’s subject matter jurisdiction. McWeeny v. City of Hartford, 287 Conn. 56, 63-4, 946 A.2d 862 (2008). As set forth below, the court finds that the Petitioner has standing to file this petition under the GRAP.

I. The Gaming Revenue Allocation Plan

As part of the GRAP, the Tribe has made provision for the future welfare of its minor tribal members by contributing their per capita benefits to grantor trusts owned by the Tribe “to be invested, with income on trust principal to be accumulated, for future distribution to those minor tribal members.” MTC § 2-181; Thomas Belisle, Jr. Petitioner, In Re: M.B. and C.B. (Minor Children), 1 M.T.C.R 60, 7 Am. Tribal Law 343, 2008 WL 5501085 (2008); Rebecca Cloutier, Petitioner, In Re: A.C. (Minor Child), 1 M.T.C.R 50, 6 Am. Tribal Law 461, 2006 WL 6177325 (2006); Scott Quidgeon, Petitioner, In Re: T.T. and T.T.(Minor Children), 1 M.T.C.R 46, 6 Am. Tribal Law 456, 2006 WL 6177326 (2006). The GRAP indicates that the Tribe shall provide for the future welfare of its minor tribal members, but that tribal member parents are encouraged to pay for the immediate living needs of their children. MTC § 2-181. No distributions may be made from the grantor trusts until the minor is eighteen years old, except in limited extraordinary circumstances.

All assets accumulated in the grantor trusts for future distribution to a minor tribal member shall be distributed at such time as the minor reaches the age of eighteen (18) and not before, except in the limited, extraordinary circumstances provided in Subsection 2-183(h)(5) (emphasis added).

MTC § 2-181.

The limited extraordinary circumstances under which distributions may be made from trusts for the benefit of minor tribal members are as follows:

Prior to the time the beneficiary reaches the age of eighteen (18), the Tribal Court may, after careful consideration of the facts, authorize the trustee or trustees of the trust or trusts to make distributions from the trust or trusts to the parents or guardians of the beneficiary only to defray unreimbursed medical expenses or only as necessary to defray expenses for health, education, or welfare incurred by or on behalf of the beneficiary as established by such parents or guardians. Any request for such disbursements shall include a detailed budget of monies necessary for essential living expenses to include health, education, or welfare costs and only upon presentment of a detailed justification for such essential living needs. The petitioning parent or guardian must show, by a preponderance of the evidence, that the amount requested to defray unreim-bursed medical expenses or expenses for health, education or welfare, are reasonable and necessary. The Tribal Court may also require that the petitioning parent or guardian submit receipts of expenditures made from funds disbursed hereunder before any future disbursements are made (emphasis added).

[364]*364MTC § 2-183(h)(5); see also; Seidel v. Mohegan Tribe, 1 M.T.C.R 38, 39, 6 Am. Tribal Law 449, 2005 WL 6238704 (2005).

A. Standing to Petition for Early Distribution

Under the GRAP, the parent or guardian of a trust beneficiary may petition the Court for a trust distribution before the minor reaches the age of eighteen. MTC § 2—183(h)(5). In this ease, however, Petitioner is the trust beneficiary. Although she has living parents, the Petitioner is an emancipated minor (Ex. 1). The effects of her emancipation include the following: her parents are no longer her guardians, Conn. Gen.Stat. § 46b-150d(k); they are relieved of all obligation to support her, Conn. Gen.Stat. § 46b-150d(m); and Petitioner may sue in her own naine. Conn. Gen.Stat. § 46b-150d(c).1

Although Petitioner is still a minor, she no longer has any guardian. Further, her parents have not supported her since her emancipation. Therefore, they would not have standing to petition for an early distribution, since such distributions are to be used only to defray expenses for a minor’s health, education and welfare. Petitioner’s parents have no such expenses because they do not provide her with any financial support. However, it would thwart the essential purpose of MTC § 2-183(h)(5), that is to meet the essential needs of Tribal children, if this provision of the GRAP were interpreted such that no person had standing to petition for an early distribution. “It is ... a fundamental principle of statutory construction that courts must interpret statutes using common sense and assuming that the legislature intended a rational result ... Courts also must not interpret statutes in such a manner so as to thwart their purpose.” State v. Wilcox, 105 Conn.App. 24, 27, 936 A.2d 295 (2007). Consistent with these principles of statutory construction, the Court finds that Petitioner, as an emancipated minor, stands in the shoes of her parents, formerly her guardians, so that she has standing to file this petition for early distribution.

B. Extraordinary Circumstances for Early Trust Distributions

The Tribal Council has expressed a clear intent in the GRAP to limit distributions from grantor trusts to extraordinary circumstances, where the amounts requested are reasonable and necessary. Further, the Tribal Court is limited to authorizing distributions from trust only where it has made a factual determination that the distributions are “necessary to defray expenses for health, education or welfare

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Related

State v. Wilcox
936 A.2d 295 (Connecticut Appellate Court, 2007)
McWeeny v. City of Hartford
946 A.2d 862 (Supreme Court of Connecticut, 2008)
Seidel v. Mohegan Tribe of Indians of Connecticut
6 Am. Tribal Law 449 (Mohegan Trial Court, 2005)
Quidgeon
6 Am. Tribal Law 456 (Mohegan Trial Court, 2006)
Cloutier
6 Am. Tribal Law 461 (Mohegan Trial Court, 2006)
Belisle
7 Am. Tribal Law 343 (Mohegan Trial Court, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
7 Am. Tribal Law 361, 1 M.T.C.R. 75, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-woodmancy-moheganct-2008.