June McGaha v. Suzanne McGaha

CourtKentucky Supreme Court
DecidedSeptember 21, 2022
Docket2021 SC 0351
StatusUnknown

This text of June McGaha v. Suzanne McGaha (June McGaha v. Suzanne McGaha) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
June McGaha v. Suzanne McGaha, (Ky. 2022).

Opinion

RENDERED: SEPTEMBER 22, 2022 TO BE PUBLISHED

Supreme Court of Kentucky 2021-SC-0351-DG

JUNE MCGAHA AND MARK MCGAHA APPELLANTS

ON REVIEW FROM COURT OF APPEALS NO. 2019-CA-1752 RUSSELL CIRCUIT COURT NO. 14-CI-00364

V.

SUZANNE MCGAHA AND CLIFFMAN MCGAHA APPELLEES

OPINION OF THE COURT BY CHIEF JUSTICE MINTON

REVERSING

Appellants bring this appeal to challenge a decision of the Court of

Appeals that reversed the circuit court’s order in a will-contest case denying

Appellees’ motion for leave to file an amended answer to assert a cross-claim

and dismissing the underlying case. The Court of Appeals remanded the

matter back to the circuit court for further proceedings, holding that the circuit

court erred in denying Appellees’ motion for leave to amend.

On discretionary review, we reverse the Court of Appeals’ decision for

failing as a reviewing court to give proper deference to the trial court’s decision

to deny Appellees leave to amend a pleading. In reaching this holding, we also

hold that the Court of Appeals erred when it found that the district court

lacked jurisdiction to probate the will at issue in this action. Accordingly, we reverse the opinion of the Court of Appeals and reinstate the circuit court’s

order dismissing this action.

I. FACTS AND PROCEDURAL BACKGROUND

At the time of his death, Leon McGaha was married to June McGaha, his

second wife. Leon1 had three adult children from his first marriage, Mark,

Damon, and Suzanne McGaha, and a grandson, Cliffman “Cliff” McGaha.

In September 2013, Leon, who was in failing health, executed a Durable

Power of Attorney (DPOA) naming June and Mark his attorneys-in-fact.

According to some family members, Leon expressed a desire upon his passing

to divide his estate equally among his grown children.

On April 3, 2014, Leon executed a will nominating June and Mark as

co-executors of his estate. The will gave Leon’s tire business, including real

and personal property associated with it, to Mark. June was to receive the

residence and farm where she and Leon lived, a farm bank account, and some

personal property. The will bequeathed to Suzanne and Cliff part of the

proceeds from the sale of cattle and some personal property. And the will made

bequests for June’s children from a prior marriage. June, Mark, and Suzanne

shared equally under the will the division of the residual estate. Damon

received nothing under the will.

1 We refer to each member of the McGaha family by his or her first name for clarity.

2 On April 4, 2014, the DPOA was recorded. That same day, June, acting

as Leon’s attorney-in-fact, conveyed the real property associated with the tire

business to Mark and Mark’s wife.

Leon died on April 7, 2014. In May 2014, the Russell District Court

entered an order probating Leon’s will and appointing June as executor of

Leon’s estate. The probate petition listed Mark and June as petitioners and

provided contact information for attorney Matthew DeHart. The petition was

not signed. June and Mark filed a fiduciary bond and filed an inventory and

appraisement of Leon’s estate.

In November 2014, Damon filed an action in Russell Circuit Court

challenging the validity of Leon’s will and asserting claims of undue influence

and breach of fiduciary duty by June and Mark. He also named other

defendants in the complaint, including Suzanne and Cliff. Damon contended

that the probate petition was defective because it was neither signed nor

verified, among other reasons. Damon requested a declaration that the will

was invalid, an accounting of estate assets, and the setting aside of certain

transactions.

Suzanne and Cliff filed a joint answer to the complaint. They asked the

trial court to protect their interests under the will and asked the trial court to

declare that they did not violate any provision of the will, including the no-

contest clause. The joint answer did not expressly assert any cross-claims or

counterclaims.

3 In 2017, Suzanne and Cliff filed a motion for partial summary judgment

against June and Mark. Specifically, the motion requested that the circuit

court set aside the transfer of the real estate related to the tire business and an

allegedly premature transfer of a tractor to Mark; asked the court to order

certain proceeds and personal property be returned to Leon’s estate; and

sought the aid of the court to require Mark to account for all profits and

receipts from the tire business since Leon’s death.

June and Mark responded to the motion for partial summary judgment,

arguing, among other things, that Suzanne and Cliff lacked standing to seek

relief because they had asserted no claims against June and Mark. Damon

also responded, indicating his agreement with the arguments Suzanne and

Cliff made in their motion. After a hearing, the circuit court denied the motion

as premature.

In August 2019, Damon settled his claims against June and Mark. A

notice of dismissal acknowledging the settlement was filed with the circuit

court by Damon’s counsel on August 1, 2019.2

On August 6, 2019, Suzanne filed a motion styled as a motion for leave

to amend her answer and to assert cross-claims and her objection to a

dismissal of the action. Cliff did not join Suzanne’s motion, but Suzanne

2 In its opinion below, the Court of Appeals acknowledged that there was no dispute as to the filing of the notice of appeal but stated that it was neither provided with a copy of the notice of dismissal nor did the notice appear in the record. The notice of appeal appears in the record before this Court as Appendix 6 to Appellants’ principal brief.

4 stated in the motion that neither she nor Cliff consented to dismissal of the

action. An affidavit from Damon’s counsel was attached to Suzanne’s

supporting memorandum in which Damon’s counsel averred that counsel

signed a notice of dismissal based on representations from June and Mark’s

counsel that June and Mark would delay filing the notice of dismissal, pending

settlement negotiations with Suzanne and Cliff. In her tendered amended

answer, Suzanne alleged that June and Mark tortiously interfered with a valid

devise and breached fiduciary duties. She also sought a declaration that Leon

lacked testamentary capacity and that June and Mark exercised undue

influence.

After several hearings on Suzanne’s motion for leave to amend, the

circuit court took the matter under advisement without issuing any oral ruling.

Then, on November 7, 2019, the circuit court issued the following order:

Comes the Court on the defendant, Suzanne McGaha's, Motion to Amend Answer and to add Crossclaim against the defendants, June McGaha and Mark McGaha. The Court having read the memorand[a] and briefs of the parties in support thereof and against the motion, and the Court being sufficiently advised, it is hereby ORDERED and ADJUDGED that Suzanne McGaha's motion is hereby OVERRULED and consequently, as a result, there are no other issues before the Court in this matter with the plaintiff having settled his claim, and therefore, this action is hereby DISMISSED AS SETTLED. This is a final and appealable order and there is not just cause for delay.

Suzanne and Cliff appealed. Noting the “terse” nature of the circuit

court’s order, the Court of Appeals “presume[d] the trial court must have

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June McGaha v. Suzanne McGaha, Counsel Stack Legal Research, https://law.counselstack.com/opinion/june-mcgaha-v-suzanne-mcgaha-ky-2022.