Meehan

8 Am. Tribal Law 227, 1 M.T.C.R. 96
CourtMohegan Trial Court
DecidedMay 4, 2009
DocketNo. CV-09-0101
StatusPublished
Cited by1 cases

This text of 8 Am. Tribal Law 227 (Meehan) 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
Meehan, 8 Am. Tribal Law 227, 1 M.T.C.R. 96 (Mo. 2009).

Opinion

JANE W. FREEMAN, Judge.

MEMORANDUM OF DECISION

The Petitioner, Susan Wendy Meehan, has petitioned the Court to authorize distributions from the grantor trust established by the Mohegan Tribe (“Tribe”) for the benefit of her minor child, C.M. The Tribe contributes per capita benefits to these 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 and the minor child are members of the Tribe and the Tribe is a party to the proceeding. The Court also has subject matter jurisdiction pursuant to the Gaming Revenue Allocation Plan, MTC § 2-181, et. seq. (“Plan”). Under the Plan, the Court 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 limited extraordinary circumstances in MTC § 2—183(h)(5).

A Guardian Ad Litem (“GAL”) has been appointed to investigate and recommend to the Court whether the early disbursement requested meets the limited extraordinary circumstances outlined in the Plan 1 and if such a disbursement is ordered, then to recommend the manner in which funds should be disbursed.2

1. The Gaming Revenue Allocation Plan

As part of the Plan, the Tribe has made provisions for the future welfare of its minor tribal members by contributing [229]*229their 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., 1 M.T.C.R 60, 7 Am. Tribal Law 343 (2008); Rebecca Cloutier, Petitioner, In Re: AC., 1 M.T.C.R 50, 6 Am. Tribal Law 461 (2006); Scott Quidgeon, Petitioner, In Re: T.T. and T.T., 1 M.T.C.R 46, 6 Am. Tribal Law 456 (2006). The Plan provides that the Tribe shall provide for the future welfare of its minor tribal members, but 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 Tribal Council deems appropriate but not before the minor reaches the age of eighteen (18), 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 trastee or tras-tees 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).

MTC § 2—183(h)(5); see also Thomas Belisle, Jr., Petitioner, In Re: M.B. and C.B., supra, 1 M.T.C.R. at 61, 7 Am. Tribal Law at 345; Rebecca Cloutier, Petitioner, In Re: AC., supra, 1 M.T.C.R. at 51, 6 Am. Tribal Law at 462; Scott Quidgeon, Petitioner, In Re: T.T. and T.T., supra, 1 M.T.C.R. at 47, 6 Am. Tribal Law at 458; Seidel v. Mohegan Tribe, 1 M.T.C.R. 38, 39, 6 Am. Tribal Law 449, 451 (2005).

The Tribal Council has expressed a clear intent in the Plan 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 incurred by or on behalf of the beneficiary ...” MTC § 2—183(h)(5).

“Extraordinary circumstances” are “[a] highly unusual set of facts that are not commonly associated with a particular thing or event.” Black’s Law Dictionary. 7lh Ed. “Extraordinary” has been defined as “going beyond what is usual, [230]*230regular, common or customary ... exceptional to a very marked extent.” Webster’s Third New International Dictionary. “Reasonable” has been defined as “being or remaining within the bounds of reason: not extreme: not excessive”. Id. “Necessary” has been defined as “that cannot be done without: that must be done or had: absolutely required”. Id.

Thomas Belisle, Jr., Petitioner, In Re: M B. and C.B., supra, 1 M.T.C.R. at 61, 7 Am. Tribal Law at 346; Rebecca Cloutier, Petitioner, In Re: A.C., supra, 1 M.T.C.R. at 51, 6 Am. Tribal Law at 462-463; Scott Quidgeon,, Petitioner, In Re: T.T. and T.T., supra, 1 M.T.C.R. at 47, 6 Am. Tribal Law at 458-459; Seidel v. Mohegan Tribe, supra, 1 M.T.C.R. at 39-40, 6 Am. Tribal Law at 451.

2. The Petition and the Facts

The Petitioner initially requested the Court to distribute a total of $40,000 from the minor’s trust to pay for forty (40) hours per week of skilled nursing care for the minor child and to pay for the costs of paving a driveway at the family home. Subsequently, the Petitioner filed an amended petition (Pleading #111) in which she eliminated the request for a disbursement to pay for skilled nursing care. At the hearing on the amended petition, Petitioner informed the Court that she was no longer requesting a trust distribution for forty (40) hours of skilled nursing care because a long term care policy recently purchased by the Tribe would pay for that care.3

The Petitioner requests a distribution from the minor child’s trust to pay the costs for paving a driveway at the family home in Oakdale, Connecticut, which she says is necessary for the welfare of the minor child, C.M. C.M. is six and a half years (6½) old and has intractable epilepsy, an extraordinary seizure disorder. She resides in the family home with her parents and three siblings. Currently, the driveway is unpaved and full of ruts (Plaintiffs Ex. 9).

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Related

Castaneda
9 Am. Tribal Law 318 (Mohegan Trial Court, 2010)

Cite This Page — Counsel Stack

Bluebook (online)
8 Am. Tribal Law 227, 1 M.T.C.R. 96, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meehan-moheganct-2009.