Smith v. Brannan

CourtSuperior Court of Maine
DecidedJune 12, 2002
DocketKNOcv-01-058
StatusUnpublished

This text of Smith v. Brannan (Smith v. Brannan) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Brannan, (Me. Super. Ct. 2002).

Opinion

SUrinc02 COURT

STATE OF MAINE SUPERIOR COURT WIN 4 4 9909 CIVIL ACTION KNOX, ss. JUN LS Lule DOCKET NO. CV-01-058 JRA -KNO~ efia- Javon ECE RD A? PRISCILLA ADAMS SMITH, ¢.. 00 fcthaten FF Usan Gadiuelie, U.erk Plaintiff v. DECISION AND ORDER JAMES W. BRANNAN . and KAYE PARKER JEX, ORALD L. GARBRECHT : AW LIBRARY Defendants

[JUN 26 2002 I. Introduction.

This matter is before the court on the motion of defendant Kaye Parker Jex (Jex) to dismiss this action against her. She relies on two bases to achieve this end. The first is that this court lacks personal jurisdiction over her and the second is that the plaintiff lacks standing to assert the claim against her.

For the reasons set forth herein, the motion is to be denied.

Il. Lack of Personal Jurisdiction..

Pursuant to M.R. Civ. P. 12(b)(2), a defendant may seek dismissal of an action pending against her for lack of personal jurisdiction. Jex has asserted in her motion that her actions as they may relate to the plaintiff occurred in Connecticut and not in Maine so that the latter's courts may not exercise jurisdiction over her.

Maine's long-arm statute, 14 M.R.S.A. § 704-A(1), provides that Maine citizens are to have an effective means of redress against a non-resident "who, through certain significant minimal contacts with this State, incur obligations to citizens entitled to the State's protection." Accordingly, any person who does any act in this State, including

the transaction of any business, or the "[dJoing or causing a tortious act to be done, or causing a tortious act to be done, or causing the consequences of a tortious act to occur within this State,” submits herself to the jurisdiction of the courts of this State. 14M RS.A.§ 704-A(2)(A), (B).

The exercise of personal jurisdiction over a nonresident by our courts pursuant to this statute is permissible as long as that use of power is consistent with the Due Process Clause of the United States Constitution. Suttie v. S loan Sales, Inc., 1998 ME 121, { 4; 711 A.2d 1285, 1286. That being so, in applying our long-arm statute, this court need only consider "whether due process requirements have been satisfied." Id. (citing Mahon v. East Moline Metal Prods., 579 A.2d 255, 256 (Me. 1990)). Those due process requirements are that: (1) Maine "have a legitimate interest in the subject matter of the controversy"; (2) the defendant by [her] conduct "reasonably could have anticipated litigation in Maine"; and (3) the exercise of jurisdiction by our courts "comports with traditional notions of fair play and substantial justice." Murphy v. Keenan, 667 A.2d 591, 593 (Me. 1995).

When a defendant, as here, challenges the exercise of personal jurisdiction over her, the plaintiff has the burden of persuasion to establish that jurisdiction is proper under the first two parts of this test. Id. at 594. This obligation may be met via specific facts alleged in the record which is to be "construed in a light most favorable to the plaintiff." Suttie v. Sloan Sales, id. at J 4. Once the plaintiff has made this showing, the burden shifts to the defendants to address the third due process requirement, that is, she is to "establish that asserting jurisdiction does not comport with traditional motions of fair play and substantial justice. Id.

In this case, the plaintiff, Priscilla Adams Smith (Priscilla), alleges that Jex

tortiously interfered with an expectancy interest from her husband, Richard's, estate. Expressed in a shorthand way, Priscilla claims that Richard promised her that his will or estate plan would provide her with $3,000 a month in income upon his death. She says that Richard went to attorney James W. Brannan (Brannan), a co-defendant in this action, on October 28, 1997, in order to effectuate this plan by having his estate plan or will altered so that she would receive this "annuity." She further states that on this occasion Richard and Brannan had a telephone conference call from Brannan's Rockland office with Jex, who was Richard's "primary estate planning attorney,” Complaint, { 38, with instructions relayed to her that his will be amended to provide for this monthly income for Priscilla after his death. Priscilla alleges that Jex argued against a change because it would be prejudicial to Richard's children who would be dependent upon the residuary trust created by his estate plan for their benefit because it would require invasion of the principal of this trust to satisfy payment of this monthly sum to Priscilla. It is alleged that further argument and discussion occurred among Richard, Brannan and Jex with Richard continuing to insist that his estate plan be altered as he wished. Ultimately, the plaintiff alleges, Jex instructed Brannan to draft an amendment to the deed of trust so that it provided for a payment to Priscilla of $3,000 per month from the marital trust, as opposed to the residuary trust, which had been created by the estate plan. In accordance with these instructions, Brannan drafted the amendment and faxed a copy to Jex for her approval which she thereafter provided. On October 31, 1997, Richard returned to Brannan's office and executed the amendment to the trust. It was sent back to Connecticut where it was accepted by the trustees in the presence of, and after consultation with, Jex. Throughout these transactions, the plaintiff states, Jex knew that under the estate plan the residuary trust was to be funded by the first

$625,000 of Richard's intangible assets in order to take advantage of the unified estate tax credit under federal estate tax law and that only the balance would fund the marital trust created under the plan. Further, it is alleged that Jex knew that the balance of Richard's assets would be insufficient to fund the residual trust at the level of $625,000 so that the marital trust would be unfunded and Priscilla would never receive a $3,000 monthly payment from it. Instead, she claims, under the estate plan she would only receive payments from the residuary trust as its trustee, in his discretion, might allow. Because the trustee, Richard's son-in-law, would benefit indirectly from the residuary trust, it would be unlikely that he would make any payments from it to Priscilla. Since Richard's death in 1998 and the admission of his will to probate, the personal representative and the trustee of the residuary trust have told Priscilla, through Brannan, that she would receive no payments from her late husband's estate. All this being so, Priscilla claims, Jex misled her client Richard into believing that his estate plan would provide for this widow's welfare via a $3,000 monthly stipend from his estate plan's marital trust when, in fact, she knew that was not possible because it would be unfunded. She says Jex did this in order to preserve Richard's estate for the benefit of his children with whom she had a relationship as a friend and as an attorney. She claims that Jex did this to interfere with and frustrate Richard's estate plan and Priscilla's expectancy interest.

In her complaint, Priscilla cites a number of Maine connections to the events which she alleges underlie her action against Jex. They may be briefly restated as follows:

- In 1991 Jex drafted the antenuptial agreement for Richard and Priscilla at

which time Priscilla was a Maine resident. At the same time Jex drafted a will for Richard, then a Connecticut resident, which was to be coordinated with the prenuptial agreement.

On November 8, 1991, Richard and Priscilla married and moved to Priscilla's home in Rockland, Maine, where Richard "took up residence." Complaint, { 10.

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Smith v. Brannan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-brannan-mesuperct-2002.