Langbehn v. Langbehn

2025 S.D. 11
CourtSouth Dakota Supreme Court
DecidedFebruary 26, 2025
Docket30211
StatusPublished
Cited by1 cases

This text of 2025 S.D. 11 (Langbehn v. Langbehn) is published on Counsel Stack Legal Research, covering South Dakota Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Langbehn v. Langbehn, 2025 S.D. 11 (S.D. 2025).

Opinion

#30211-aff in pt & rev in pt-MES 2025 S.D. 11

IN THE SUPREME COURT OF THE STATE OF SOUTH DAKOTA

****

CIV 19-193

MARY L. LANGBEHN, as sole income Beneficiary and co-trustee of the Richard K. Langbehn Revocable Living Trust Agreement, Plaintiff and Appellee,

v.

MICHAEL LANGBEHN, and LANGBEHN LAND & CATTLE CO., INC., Defendants and Appellants. --------------------------------------------------------------- CIV 19-192

MARY L. LANGBEHN, as sole income Beneficiary and co-trustee of the Mary L. Langbehn Revocable Living Trust Agreement, Plaintiff and Appellee,

MICHAEL LANGBEHN, and LANGBEHN LAND & CATTLE CO., INC., Defendants and Appellants.

--------------------------------------------------------------- CIV 19-216

MARY L. LANGBEHN, Plaintiff and Appellee,

LANGBEHN LAND & CATTLE CO., INC., Defendant and Appellant.

APPEAL FROM THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT BEADLE COUNTY, SOUTH DAKOTA

**** ARGUED AUGUST 31, 2023 OPINION FILED 02/26/25 ****

THE HONORABLE PATRICK T. PARDY Judge

STACY R. HEGGE QUENTIN L. RIGGINS of Gunderson, Palmer, Nelson & Ashmore, LLP Pierre, South Dakota Attorneys for defendants and appellants.

MICHAEL F. STEVE JESS M. PEKARSKI of Costello, Porter, Hill, Heisterkamp, Bushnell & Carpenter, LLP Rapid City, South Dakota Attorneys for plaintiff and appellee. #30211

SALTER, Justice

[¶1.] Mary Langbehn sued her son, Michael Langbehn, and his company,

Langbehn Land and Cattle Co. (LL&C), alleging Michael breached his fiduciary

duty as a co-trustee of his deceased father’s trust. Michael filed counterclaims for

unjust enrichment and quantum meruit relating to improvements he claimed to

have made to real estate he leased from his father’s trust and Mary’s separate living

trust. The circuit court granted summary judgment in favor of Mary on her claims

as well as on Michael’s counterclaims. The court also removed Michael as a co-

trustee and awarded Mary $513,796.94 in damages. Michael appeals. We reverse

in part, affirm in part, and remand for further proceedings.

Factual and Procedural History

[¶2.] Richard and Mary Langbehn were a married couple who owned and

farmed a substantial amount of crop and pastureland in Beadle County. In 2007,

Richard and Mary each executed reciprocal trust agreements. These trust

agreements created individual revocable living trusts—the Mary Langbehn

Revocable Living Trust and the Richard Langbehn Revocable Living Trust. Each

living trust named both spouses as co-trustees, named the other spouse’s trust as a

beneficiary, and was funded with a fifty percent interest in the couple’s real

property. The couple’s trust agreements also provided for the creation of a credit

exemption trust upon the death of the grantor in the event the other spouse was

-1- #30211

still living, with the surviving spouse designated as the income beneficiary and

Richard’s and Mary’s son, Michael, as the remainder beneficiary. 1

[¶3.] Richard passed away in March 2008. Pursuant to his living trust, his

death prompted the creation of the Richard K. Langbehn Credit Exemption Trust

(the credit trust) into which was transferred his undivided one-half interest in the

couple’s real estate. As a result, all of the Langbehns’ agricultural land is either

owned jointly by the credit trust and Mary’s living trust or exclusively by Mary’s

living trust; the credit trust does not solely own any of the land.

[¶4.] Pursuant to Richard’s trust agreement, Mary, Michael, and a corporate

trustee became co-trustees of the credit trust. 2 Among its other provisions, the

credit trust recited Richard’s intent “that the amount of rent that the Trust charges

my son, Michael, for the rent of the farm real estate is not as important to me as the

right of my son, Michael, to have the use of such land. Therefore, I direct that the

land may be rented for less than fair rental value.”

[¶5.] Prior to Richard’s passing, Richard, Mary, and Michael together had

formed LL&C as part of their farming operation. Upon Richard’s passing, Richard’s

1. A credit exemption trust, also known as a credit shelter trust or a credit trust, is designed to maximize a married couple’s unified credit against federal estate and transfer tax. See Jay A. Soled, A Proposal to Make Credit Shelter Trusts Obsolete, 51 Tax Law. 83, 88 (1997). For example, the credit exemption trust portion of Richard’s trust agreement states that it will be funded at his death, should Mary survive him, with “such amount of [his] adjusted gross estate as shall increase [his] taxable estate for federal estate tax purposes to the largest amount which will . . . result in no federal estate tax being payable by [his] estate[.]”

2. Richard’s death also meant that Mary became the sole trustee of Mary’s living trust.

-2- #30211

interest in LL&C was transferred to Michael under the terms of Richard’s living

trust. Mary subsequently gifted her interest in LL&C to Michael, making him the

sole owner. Additionally, Mary had earlier executed a general power of attorney

that made Richard her attorney-in-fact and, upon Richard’s death, appointed

Michael to serve as Richard’s successor.

[¶6.] In 2009, Mary entered into a ten-year lease agreement to lease 1,299

acres of cropland and 1,579 acres of grassland to Michael, through LL&C. While

the lease does not indicate in what capacity Mary signed, it appears she was acting

in her capacity as a trustee of the credit trust and her own living trust. The land

included in the lease was owned jointly by the credit trust and by Mary’s living

trust, as tenants in common, along with land that was owned by Mary’s living trust.

The parties agree that the land was leased to LL&C at a rate below the fair market

value—the cropland was leased at a rate of $50.00 per acre and the grassland was

leased at a rate of $19.00 per acre.

[¶7.] The justification for the lower rent was sourced to the provision in the

credit trust that authorized below-market rental rates for Michael, which Mary

apparently extended to Michael’s corporation, LL&C. And because the credit trust

did not own any real estate of its own, it appears Mary also agreed on behalf of her

living trust to lease the land at the lower rent, both for land owned jointly with the

credit trust land as well as the land held separately by her living trust. 3

3. In some of her submissions to the circuit court, Mary suggests that the provision authorizing below market rent for Michael also applied to her by virtue of the reciprocal credit trust provision contained in her living trust instrument. The circuit court noted this argument as well, and though it (continued . . .) -3- #30211

[¶8.] Michael, through LL&C, farmed the land for several years until 2018

when he reportedly experienced medical issues and was temporarily unable to

continue farming. The ten-year lease with Mary did not contain a prohibition upon

subleasing, and, faced with these circumstances, Michael entered into a three-year

sublease beginning on April 9, 2018, with a third party, Jack Steele. Steele rented

1,152.05 acres, 983.03 of which were owned jointly by the credit trust and Mary’s

living trust and 89.02 of which were owned solely by Mary’s living trust. This land

was subleased at a rate of $63.60 per acre. Michael signed the lease on behalf of

LL&C and as a trustee of the credit trust.

[¶9.] In May 2018, Michael, on behalf of LL&C, entered into another

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Trigger Energy Holdings v. Stevens
2025 S.D. 72 (South Dakota Supreme Court, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2025 S.D. 11, Counsel Stack Legal Research, https://law.counselstack.com/opinion/langbehn-v-langbehn-sd-2025.