Margaret C. Ughetta v. Mary Harding Cist, individually, as of Estate of John David Cist, and as Trustee of the Supp Trust Agreement of John David Cist

CourtCourt of Chancery of Delaware
DecidedMay 29, 2015
DocketCA 7885-MA
StatusPublished

This text of Margaret C. Ughetta v. Mary Harding Cist, individually, as of Estate of John David Cist, and as Trustee of the Supp Trust Agreement of John David Cist (Margaret C. Ughetta v. Mary Harding Cist, individually, as of Estate of John David Cist, and as Trustee of the Supp Trust Agreement of John David Cist) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Margaret C. Ughetta v. Mary Harding Cist, individually, as of Estate of John David Cist, and as Trustee of the Supp Trust Agreement of John David Cist, (Del. Ct. App. 2015).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

Margaret C. Ughetta, ) Petitioner ) C.A. No. 7885-MA ) v. ) ) Mary Harding Cist, individually, as ) Executrix of the Estate of John David ) Cist, and as Trustee of the Supplemental ) Trust Agreement of John David Cist, ) Respondent )

MASTER’S REPORT

Date Submitted: January 7, 2015 Draft Report: Final Report: May 29, 2015

One of four beneficiaries of a now-irrevocable trust contends that the

successor trustee should be removed for alleged breaches of fiduciary duty. The

successor trustee denies these claims and, in turn, seeks to forfeit 50 percent of this

beneficiary’s trust share under the no-contest provision of the trust agreement.

The four beneficiaries, one of whom is the successor trustee, are the

surviving children of a married couple, each of whom settled a trust for the benefit

of themselves and their children. The beneficiaries’ mother predeceased their

father, and upon the father’s death two years later, his successor trustee was

directed by the provisions of the father’s trust agreement to equalize the couple’s

lifetime and post-mortem gifts to their four children. Petitioner has questioned the

Page 1 of 46 successor trustee’s administration of the father’s trust. In 2011, after the

beneficiaries all participated in a distribution the trust’s tangible personal property

(hereinafter “TPP”), petitioner refused to sign a receipt and release agreement. As

a result, her TPP remains in storage controlled by the father’s trust while her three

siblings have taken possession of their TPP. Likewise, petitioner is dissatisfied

with the process undertaken to equalize the beneficiaries’ shares of their parents’

lifetime and post-mortem gifts. Petitioner now contends that the equalization

process was inconsistent with the terms of the father’s trust agreement.

For the reasons that follow, I conclude that the successor trustee properly

exercised her discretion in distributing the TPP and in following the equalization

process established originally by the trustor during his lifetime. However, I also

conclude that the beneficiary has not challenged the disposition or validity of the

trust, but instead sought only to ensure its proper administration. As a result, she

has not triggered the no-contest provision of the trust agreement. In order not to

prolong this litigation, I am waiving a draft report and issuing this as my final

report.

I. FACTUAL BACKGROUND

The trustor, John David Cist (hereinafter “Mr. Cist”) and his wife Mary S.

Cist (hereinafter “Mrs. Cist”) were the parents of four children: Dorothea Cist,

Margaret C. Ughetta, David Cist, and Mary Harding Cist. During their lifetimes,

Page 2 of 46 Mr. and Mrs. Cist were financially comfortable as a result of their own investments

and family inheritances.1 They accumulated possessions, including family

heirlooms, and were reluctant to dispose of anything. At the same time, however,

Mr. and Mrs. Cist were generous parents. They provided each of their children

with a private college education and a credit card on the parents’ account, and also

paid some of the private school tuition of their grandchildren, among other gifts.

Dorothea and Mary Harding apparently never married and have no children.2

Margaret and her husband have four children who were in high school and college

when Margaret filed her petition for an accounting and to remove Mary Harding as

successor trustee. David and his wife have two younger children.

On May 21, 1991, Mr. and Mrs. Cist executed wills3 and entered into trust

agreements in their respective capacities as trustor of his and her own trust and as

co-trustees of both trusts.4 The provisions of Mr. Cist’s trust agreement included

the division of the trust fund upon his death, if his wife survived him, into a

Unified Credit Generation Skipping Transfer (“GST”) Trust, a Marital GST Trust,

a Marital Trust and, possibly, a Resulting Trust. On June 30, 1993, Mr. Cist

1 Respondent Mary Harding Cist’s Single Compilation of Appendices (hereinafter “Mary Harding Compilation”) at 2 (Affidavit of Mary Harding Cist). 2 I use first names here for the sake of clarity, and intend no disrespect. 3 Mary Harding Compilation at 130-156 (Wills of John David Cist and Mary S. Cist). 4 Id. at 10-54 (Trust Agreement between John David Cist, Trustor and John David Cist and Mary S. Cist, Trustees). Page 3 of 46 executed a Supplemental Trust Agreement, in which he modified two sections that

are not relevant here.5 Mrs. Cist’s trust agreement and supplemental trust

agreement contained reciprocal provisions for the benefit of her husband, and

identical provisions for her children.6

A. Fairness Concerns

In 2006, David became aware that Margaret was receiving from her parents

more gifts of family heirlooms than her siblings.7 In a letter to his parents, David

expressed his concern that jewelry, silverware, china, paintings, and furnishings

“were leaking away” “by gift or eminent domain,” giving rise to the appearance of

favoritism.8 In his letter, David stated that he was not concerned about monetary

matters because he predicted that his parents’ assets after taxes could be equalized

without much difficulty despite the large sums of money or assets that already had

been given to their four children.9 However, David implored his parents to be fair

5 Id. at 55-62 (Supplemental Trust Agreement between John David Cist, Trustor and John David Cist and Mary S. Cist, Trustee). 6 Id. at 175 (Supplemental Trust Agreement between Mary S. Cist, Trustor, and Mary S. Cist and John David Cist, Trustees Dated December 20, 2006). Although the record does not include Mrs. Cist’s pre-2006 trust documents, the similarity of the couple’s 2006 Supplemental Trust Agreements and the coordinated history of their estate planning leads me to believe this was the case. 7 Id. at 425 (Deposition of David B. Cist). 8 Id. at 502-503 (letter from David dated about October 2008). 9 Id. at 502. The large blocks to which David was referring in his letter were gifts of a house to David, a house to Mary Harding, financial assistance to Dorothea, and tuition payments for Margaret’s children. Page 4 of 46 to the rest of their children when it came to the distribution of “historically

important family artifacts.”10

David’s letter may have prompted Mr. and Mrs. Cist to reconsider their

estate plans because on December 20, 2006, Mr. Cist executed another

Supplemental Trust Agreement, in which he modified his previous trust agreement

by restating it completely.11 Mr. Cist’s 2006 Supplemental Trust Agreement

provided for the distribution of the trust fund, upon Mr. Cist’s death, into: (1) a

Generation-Skipping Transfer Tax Exemption Trust (hereinafter “GST”); (2) a

Marital Trust in the event that Mrs. Cist survived her husband; and (3) a Residuary

Trust. The provisions of the Marital Trust were complex and allowed Mrs. Cist to

occupy the family residence in Wilmington, Delaware, for the rest of her life and,

upon Mrs. Cist’s death, provided for the transfer of this residence to Mary Harding,

outright and free from trust.12 The remaining Marital Trust was to be divided in

equal shares for his children, with the following provisos: (1) the amount of

10 Id. at 503. 11 Id. at 63-116 (Supplemental Trust Agreement between John David Cist, Trustor, and John David Cist and Mary S. Cist, Trustees dated December 20, 2006). Mr.

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Margaret C. Ughetta v. Mary Harding Cist, individually, as of Estate of John David Cist, and as Trustee of the Supp Trust Agreement of John David Cist, Counsel Stack Legal Research, https://law.counselstack.com/opinion/margaret-c-ughetta-v-mary-harding-cist-individuall-delch-2015.