Martone v. Martone

43 Va. Cir. 155, 1997 Va. Cir. LEXIS 345
CourtNorfolk County Circuit Court
DecidedJuly 23, 1997
DocketCase No. (Chancery) C95-1315
StatusPublished

This text of 43 Va. Cir. 155 (Martone v. Martone) is published on Counsel Stack Legal Research, covering Norfolk County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Martone v. Martone, 43 Va. Cir. 155, 1997 Va. Cir. LEXIS 345 (Va. Super. Ct. 1997).

Opinion

By Judge Charles E. Poston

ha this case, Joan D. Martone seeks a declaratory judgment that die trust agreement executed by her husband, Dr. Alexander L. Martone, on April 10, 1991, was validly revoked by Dr. Martone on December 21,1994; a power of attorney given by Dr. Martone to Peter W. Martone, as attorney-in-fact, on April 10,1991, was also revoked by Dr. Martone; and certain actions takes by Peter Martone, purporting to act as attorney-in-fact for Dr. Martone, including actions purporting to transfer Dr. Martone’s property to the 1991 Trust, are ineffective and void. The case is currently before the Court on a Motion for Summary Judgment filed by Joan Martone. Rule 2:21 of the Rules of the Supreme Court of Virginia provides, in pertinent part:

[Ejiifeer party may snake a motion for summary judgment at any time alter the parties at issue. If it appears from the pleadings ... [or] the admissions, if any, in the proceedings ... that die moving party is entitled to judgment, file court shall enter judgment in his favor ... Summary judgment shall not be entered if any material fact is genuinely in disputo.

[156]*156As this, rule makes clear, summary judgment is appropriate only when there exists no genuine issue as to any material fact and die moving party is «added to judgment as a matter of law. Renner v. Stafford, 245 Va. 351, 353 (1993). In ruling on a motion for summary judgment, die court must view the evidence and the inferences to be drawn therefrom in die light most favorable to die non-moving party. Renner, 245 Va. at 353. Summary judgment must be denied if, based on all die evidence, reasonable minds could differ as to die outcome of the case. Richmond, F. & P. R. Co. v. Sutton Co., 218 Va. 636, 643 (1977); Smith v. New Dixie Lines, 201 Va. 466, 471 (1959).

The Plaintiff argues that summary judgment is appropriate on die following grounds.

I. The level of competency or mental capacity required for Dr. Martone to make a valid revocation of the 1991 testamentary documents and power of attorney was the same mental capacity as is required to make a valid will, or at most, the mental capacity to understand the nature of the transactions and assent to their provisions.

hi a decree entered on May 9, 1997, this Court ordered the parties to submit memoranda of law on die following agreed issue:

Because die will, trust, and power of attorney given by Alexander L. Martone, deemed, to Peter Martone were all components of one estate plan, what level of competency was required for Alexander L. Martone, deceased, to revoke the power of attorney and to discharge the trustee?

It is clear that die required mentid capacity needed to revoke die 1991 will is that of testamentary capacity. A testator is deemed to have testamentary capacity if he understands die nature of the business in which he is engaged, has a recollection of die property which he means to dispose of, knows the objects of his bounty, and knows the manner in which he wishes to distribute his property among them. See, e.g., Porter v. Porter, 89 Va. 118 (1892).

The more difficult issue concerns what capacity Dr. Martone needed to possess in order to revoke die 1991 trust and power of attorney. The Plaintiff contends that because the 1991 trust, die 1991 will, and the 1991 power of attorney were all executed by Dr. Martone as parts of a comprehensive estate plan and because the primary use of the revocable 1991 trust was as a device for disposing of property at death, the testamentary capacity standard used for [157]*157wills should also be applied to die revocation of these documente.1 The Plaintiff cites the current draft of the Restatement (Third) of Trusts § 11, comment b (Tentative Draft No. 1, April 5, 1996), a draft of the Uniform Trust Act § 3-101 comment (National Conf. of Comm’rs on Unif. State Laws, Draft, October 21, 1996), and Greer v. Greers, 50 Va. (9 Gratt.) 330, 332 (1852) (capacity standard for deed intended as testamentary disposition of property should be same as that applicable to wills), in support of her position.

With a revocable inter vivos trust, the settlor may reserve a power to revoke the trust by a transaction inter vivos; however, it is unclear what capacity the settlor must possess in order to exercise this power. The Court has been unable to find any Virginia Supreme Court cases addressing the issue of capacity to revoke a trust Generally, an individual has capacity to create a trust to die same extent that the individual had the capacity to transfer property inter vivos free of trust See Restatement (Second) of Trusts, § 19; 76 Am. Jur. 2d, Trusts, § 55 at 84; see also, Hoyle v. Dickinson, 746 P.2d 18 (Ariz. App. 1987); Re Estate of Stokes, 747 P.2d 300 (Okla. 1987); Waesche v. Rizzuto, 168 A.2d 871 (Md. 1961). Thus, a valid trust can be created only where the trustor or settlor has the legal competence to make a contract and to make a disposition of the legal title to his property. See Am. Jur. 2d, Trusts, § 55 at 84; see also, Reid v. Barry, 112 So. 847 (Fla. 1927); Schumann-Heink v. Folsom, 159 N.E. 250 (Ill.1927). This is important because in dealing with documents such as wills and deeds, courts generally apply the same standards to determine competency to create die legal relationship as they do for competency to revoke die legal relationship. The few reported court decisions to address capacity to revoke a trust generally hold that a trustor merely needs to have die capacity to understand die nature of the transaction. See Freeman v. Lane, 504 So. 2d 1297 (Fla. App. Dist. 5, 1987) (bolding that despite testimony that trustor was suffering from cerebral-vascular disease, hardening of die brain arteries, and was confused and disoriented at die time of her last hospital discharge, she nonetheless had die capacity to understand the nature of the transaction when she revoked her trust, based on lack of competent, substantial evidence to the contrary). Generally, the mental capacity of a maker of a trust is presumed and the burden rests on the contestante to prove incapacity by a preponderance of the evidence. See Rose v. Dunn, 679 S.W.2d 180 (Ark. 1984).

[158]*158With a power of attorney, since this is an agency relationship and an agency is formed by contract, the mental capacity needed to enter into or revoke an agency is the same as that required to make a valid contract: the capacity to understand the nature and consequences of the transaction. Lohman v. Sherwood, 181 Va. 594, 607 (1943).

The Court concludes that the level of competency required for Dr. Martone to revoke tire power of attorney and discharge the trustee is that of contractual capacity: the capacity to understand the nature and consequences of the transition

II. It is res judicata that the 1991 will was duly revoked on March 3,1995 (if not sooner) by the valid last will and testament of Alexander L. Martone executed on that date.

In Probate No.

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43 Va. Cir. 155, 1997 Va. Cir. LEXIS 345, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martone-v-martone-vaccnorfolk-1997.