Seidel v. Mohegan Tribe of Indians of Connecticut

6 Am. Tribal Law 449, 1 M.T.C.R. 38
CourtMohegan Trial Court
DecidedOctober 26, 2005
DocketNo. CV-05-0126
StatusPublished
Cited by5 cases

This text of 6 Am. Tribal Law 449 (Seidel v. Mohegan Tribe of Indians of Connecticut) 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
Seidel v. Mohegan Tribe of Indians of Connecticut, 6 Am. Tribal Law 449, 1 M.T.C.R. 38 (Mo. 2005).

Opinion

[450]*450MEMORANDUM OF DECISION

JANE W. FREEMAN, Judge.

The Petitioner, Bethany Seidel, has petitioned the Court to authorize the distribution of per capita funds, from trust, to pay educational expenses of her two minor children, [Names Redacted] for the school year 2005—2000. The Mohegan Tribe of Indians of Connecticut (“Tribe”), Respondent, has filed an Answer indicating that it takes no position regarding the Petition.

The Court has jurisdiction of the parties and the subject matter. The Petitioner and the two minor children are members of the Tribe and the Respondent is the Tribe. The Court has subject matter jurisdiction pursuant to the Amended and Restated Ordinance of the Mohegan Tribe of Indians of Connecticut Establishing The Gaming Revenue Allocation Plan, Ordinance No. 2001-08, Section III.H.5., to authorize the trustee or trustees of trusts established for minor children Under M.T.0.2001-08 to make distributions to the parents or guardians of the trust beneficiaries, for the purposes and subject to the limitations set forth therein.

For the reasons hereafter stated, the Court holds that the Petitioner has not sustained her burden of showing, by a preponderance of the evidence, that the requested distributions from trust are necessary.

I. The Amended and Restated Ordinance of the Mohegan Tribe of Indians of Connecticut Establishing The Gaming Revenue Allocation Plan, Ordinance No. &001-08

An Indian Tribe which makes per capita payments to its members from class II net gaming revenues is required to have an approved tribal revenue allocation plan. 25 U.S.C. § 2710(b)(3)(A). The Tribe has adopted M.T.0.2001-08 to meet this statutory requirement. M.T.0.2001-08 makes provisions for the future welfare of minor tribal members while encouraging tribal member parents to pay for the immediate living needs of their children.

The tribe also retains the inherent sovereign right to determine the best interests of its minor tribal members by providing for their future welfare by contributing per capita benefits to grantor trusts owned by the Tribe to be invested, with income earned on trust principal to be accumulated, for future distribution to those minor tribal members. The Tribe shall provide for the future of minors while encouraging tribal member parents to provide for the immediate living needs of their children as is their responsibility. All assets accumulated in the grantor trusts for future distribution to a minor tribal member shall be distributed at such time as the minor reaches the age of eighteen (18) and not before, except in the limited extra,ordinary circumstances provided in Section III.F.5 1 (emphasis added).

M.T.O. No.2001-08, Section I.

The limited extraordinary circumstances under which distributions may be made from trusts for the benefit of minor tribal members are as follows:

In order to provide for the future safety and well being of tribal children, per capita benefits intended for future distribution to qualified minor tribal members shall be contributed by the Tribal Coun[451]*451cil to one or more trusts which are grantor trusts owned by the Tribe for federal income tax purposes ...
Prior to the time the beneficiary reaches the age of eighteen (18), the Tribal Court may, after careful consideration of the facts, authorize the trustee or trustees 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 unreimbursed medical expenses or expenses for health, education or welfare, are reasonable ami 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).

M.'['.0.2001-08, Section III.H.5.

The Tribal Council has expressed a clear intent in M.T.0.2001-08 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 far health, education or 'welfare incurred by or on behalf of the beneficiary ...” M.T.0.2001-08, Section III.H.5. The phrase “extraordinary circumstances” and the terms “reasonable” and “necessary” are not defined in M.T.0.2001-08. To discern the meaning of a phrase, a court may look to the word’s ordinary meaning, Jagger v. Mohawk Mountain Ski Area, Inc., 269 Conn. 672, 682, 849 A.2d 813 (2004). To ascertain the commonly approved usage of words, it is appropriate to look to the dictionary definition of the terms. Id.

“Extraordinary circumstances” are “[a] highly unusual set of facts that are not commonly associated with a particular thing or event.” Black’s Law Dictionary, 7th Ed. “Extraordinary” has been defined as “going beyond what is usual, regular, 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.

The petition must be considered in light of these definitions and the clear legislative intent to limit distributions to extraordinary circumstances where the amounts requested are reasonable and necessary.

II. The Petition and the Facts

The petitioning parent seeking a distribution from a grantor trust in order to defray educational expenses, must show, by a preponderance of the evidence, that the amount requested is reasonable and necessary. M.T.0.2001-08, Section III. H.5. The standard of proof of a fact by a preponderance of the evidence has been met when all the evidence, considered fairly and impartially, evinces a reasonable belief that it is more probable than not that the fact is true. State v. Haggood, 36 [452]*452Conn.App. 753, 653 A.2d 210, cert. denied, 233 Conn. 904, 657 A.2d 644 (1995). A hearing has been held by this Court to consider and determine the facts. In addition to considering the hearing testimony, the Court required the Petitioner to file copies of federal income tax returns for the past three years and to complete a court form entitled “Financial Disclosure Form—Petition For Distribution From Minor Child’s Trust” 2

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Cite This Page — Counsel Stack

Bluebook (online)
6 Am. Tribal Law 449, 1 M.T.C.R. 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/seidel-v-mohegan-tribe-of-indians-of-connecticut-moheganct-2005.