of Treviño

2020 COA 125
CourtColorado Court of Appeals
DecidedAugust 20, 2020
Docket19CA0199, Estate
StatusPublished
Cited by315 cases

This text of 2020 COA 125 (of Treviño) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
of Treviño, 2020 COA 125 (Colo. Ct. App. 2020).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY August 20, 2020

2020COA125

No. 19CA0199, Estate of Treviño — Nonprobate Transfers on Death — Accounts and Transfers Nontestmentary — Payable on Death Accounts

A division of the court of appeals considers to what extent a

decedent’s payable on death account was subject to the authority of

his personal representative, when the decedent had pledged the

account as collateral for a loan. The division holds that the

personal representative had authority over only the funds in the

account necessary to pay the loan in full. As to the amount over

which a personal representative has authority, a personal

representative owes fiduciary duties to the beneficiary of the

account.

Applying these principles, the division concludes that Gerardo

Treviño’s personal representative violated her fiduciary duties of good faith and impartiality when she paid a loan solely from funds

in Treviño’s POD account. COLORADO COURT OF APPEALS 2020COA125

Court of Appeals No. 19CA0199 Fremont County District Court No. 17PR30084 Honorable Stephen A. Groome, Judge

In re the Estate of Gerardo Treviño, deceased.

Esteban Treviño,

Appellant,

v.

Victoria Treviño, in her capacity as Personal Representative,

Appellee.

ORDER AFFIRMED IN PART, REVERSED IN PART, AND CASE REMANDED WITH DIRECTIONS

Division VII Opinion by JUDGE BERGER Fox and Lipinsky, JJ., concur

Announced August 20, 2020

Holder & Associates, PC, Michael D. Holder, J. David Taunton, Colorado Springs, Colorado, for Petitioner-Appellant

No Appearance for Appellee

Brown & Crona, LLC, Spencer J. Crona, Denver, Colorado, for Amicus Curiae Colorado Bar Association Amicus Brief Committee ¶1 The principal question in this case is whether and to what

extent Gerardo “Jerry” Treviño’s payable on death (POD) certificate

of deposit account (the account) was subject to the authority of his

personal representative on Jerry’s death. Usually, POD accounts

automatically pass under Colorado law to the named beneficiary

and do not become part of the probate estate or subject to the

authority of the decedent’s personal representative. § 15-15-214,

C.R.S. 2019.

¶2 Here, however, Jerry pledged the POD account as collateral for

a loan and, under the terms of the pledge agreement Jerry signed,

no beneficiary or personal representative had the right to receive

“any rights in the Collateral in the event of Debtor’s death or

incapacity until the obligations secured hereby are paid in full.”

Jerry and his wife, Victoria Treviño, were jointly and severally liable

on the loan.

¶3 When Jerry died, the amount in the account exceeded the

amount secured by the pledge agreement. We hold that appellee,

Victoria Treviño, as personal representative of Jerry’s estate, held

authority over only those funds in the account necessary to pay the

loan in full, but held no authority over the remaining funds. As to

1 the amount over which she had authority as personal

representative, she owed statutory duties of good faith and

impartiality to the beneficiary of the account. She violated these

duties when she paid the loan solely from funds in the account

without first paying down the loan from other liquid assets of the

estate.

¶4 Victoria’s actions harmed the beneficiary of the account

because she paid an outstanding debt from monies to which the

beneficiary was legally entitled, rather than using other liquid estate

assets available for that purpose.

¶5 We thus partially reverse the trial court’s order that Victoria

did not violate her fiduciary duties, and remand for further

proceedings consistent with this opinion.

I. Relevant Facts and Procedural History

¶6 The account Jerry opened was payable on death to his son,

Esteban “Tony” Treviño, the appellant. Later, Jerry and his wife,

Victoria, obtained an $80,000 secured loan from Wells Fargo Bank.

Jerry and Victoria were jointly and severally liable on the loan, for

which Jerry pledged the account as collateral. Victoria never had

any rights in the account. The pledge agreement provided “that no

2 joint owner, beneficiary, surviving spouse or representative of

Debtor’s estate gets any rights in [the account] in the event of

Debtor’s death or incapacity until the obligations secured hereby

are paid in full.”

¶7 In a separate transaction, Jerry and Victoria sold residential

real property in Texas on an installment loan basis to a family

member. Victoria testified that the monthly loan payments from the

sale of the Texas property were used to pay down the Wells Fargo

loan before Jerry’s death and that the payments on the real

property sale were roughly equivalent to the periodic payments due

to Wells Fargo.

¶8 Jerry’s will designated Victoria as his personal representative,

and she assumed that role on Jerry’s death. In her capacity as

personal representative, Victoria, through her attorneys, sent a

letter to Wells Fargo directing it to use the account to pay the

$77,212.03 balance on the loan and to distribute the remaining

$27,246.52 in the account to Tony, as POD beneficiary. The estate

(and then Victoria, as the residual beneficiary of Jerry’s estate)

continued to receive monthly payments from the sale of the Texas

property after Jerry’s death.

3 ¶9 About a year after Jerry’s death, Tony filed a petition asserting

that Jerry’s will was invalid based on Victoria’s alleged undue

influence. Later, Tony claimed that Victoria had misused the

account and breached her fiduciary duties when her lawyer directed

Wells Fargo to use the account to pay the Wells Fargo loan in full.1

Tony sought a surcharge judgment of $71,711.81 plus interest.2

¶ 10 In a written order, the trial court rejected Tony’s challenge to

the will, finding that Tony did not meet his burden of proving undue

influence. Tony does not appeal this part of the court’s order. The

trial court also rejected Tony’s claim that Victoria breached her

fiduciary duties in using the account to pay Jerry’s debt to Wells

1 Victoria testified at the trial that she never directed Wells Fargo to do anything and that the decision to use the account to pay the loan was made entirely by Wells Fargo. This contention is conclusively disproved by the letter Victoria’s lawyer sent to Wells Fargo, which said, “[o]n Ms. Treviño’s behalf, we request that Wells Fargo release the funds in the CD account to pay off the personal loan in full, and then distribute any remaining funds to [Tony].” While Victoria consistently alleged that Wells Fargo acted of its own accord in using the account, she never contested the authenticity of the letter. 2 The trial court stated in its order that “[Tony] contends that

[Victoria] breached her duty by authorizing Wells Fargo to use $71,711.81 of the proceeds of [the account] to pay off the personal loan rather than using assets of the estate to do so.” But later, the court found that the balance due on the loan was $77,212.03.

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2020 COA 125, Counsel Stack Legal Research, https://law.counselstack.com/opinion/of-trevino-coloctapp-2020.