Strauss v. Summerhays

157 Cal. App. 3d 806, 204 Cal. Rptr. 227, 1984 Cal. App. LEXIS 2248
CourtCalifornia Court of Appeal
DecidedJune 26, 1984
DocketCiv. 30471
StatusPublished
Cited by21 cases

This text of 157 Cal. App. 3d 806 (Strauss v. Summerhays) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Strauss v. Summerhays, 157 Cal. App. 3d 806, 204 Cal. Rptr. 227, 1984 Cal. App. LEXIS 2248 (Cal. Ct. App. 1984).

Opinion

Opinion

WALLIN, J.

Alta Strauss appeals a superior court judgment declaring decedent Christine E. Melcher’s Leisure World residence to be an asset of an irrevocable trust and thus not subject to testamentary disposition. Strauss contends: (1) she was improperly denied a jury trial; (2) there was a failure to join an indispensable party; and (3) transfer of the residence to the irrevocable trust was legally impossible due to restrictions imposed by Leisure World.

I

Christine E. Melcher executed a will on July 14, 1979. On October 4, 1979, she signed an irrevocable trust (the trust) prepared by Charles Benninghoff III, husband of her grandniece, Nancy Lee Benninghoff. Melcher named Dorothy Ellen Summerhays, her niece, as trustee. The trust provided for Melcher’s support during her lifetime and, upon her death, for distribution among her family members. The property transferred to the trust was listed on schedule “I” and consisted of substantially all of her assets, including her residence in the retirement community of Leisure World in Laguna Hills, California (the residence).

The ownership of the residence was signified by certificates for one membership in United Laguna Hills Mutual and Golden Rain Foundation, nonprofit corporations that own Leisure World (the Leisure World corporations). 1 The certificates were delivered to Summerhays on November 5, *811 1979, 2 but title to the certificates was never transferred on the books of the Leisure World corporations.

On June 19, 1980, Melcher executed a codicil to her will leaving her residence to Strauss, her housekeeper and friend. Melcher died on March 10, 1981.

Strauss filed an action against the Leisure World corporations and the beneficiaries and trustee of the trust to quiet title to the residence. Summer-hays, as trustee, filed a cross-complaint for declaratory relief, contending the residence was an asset of the irrevocable trust and could not pass by will. In her answer to the cross-complaint, Strauss alleged Melcher was incompetent and was the victim of fraud and undue influence by the trustee. Strauss also filed a petition for probate of the will and codicil and for letters of administration with will annexed. Summerhays, individually and as trustee, responded with a petition contesting the codicil and opposing its probate on the grounds of incompetency, undue influence and fraud (will contest).

By stipulation of the parties, the quiet title action, the cross-complaint for declaratory relief and the will contest were consolidated for trial. Strauss requested a jury trial on the consolidated cases and timely deposited the jury fees.

In chambers prior to trial, the court determined the quiet title action and the cross-complaint for declaratory relief were equitable and should be tried without a jury. Each side proposed an alternative order for proceeding. Strauss contended she was entitled to a jury trial first. The court determined the equitable issues should be tried first, since a finding that the residence was an asset of the trust would render unnecessary a trial of the will contest.

During the opening statement, Strauss announced she would make no claim against the Leisure World corporations, and dismissed them without prejudice.

At the conclusion of the evidence, the court found the residence was an asset of the trust as of October 4, 1979, and Melcher did not own it after that date. Accordingly, the will contest was dismissed. Strauss appeals.

*812 II

Strauss contends the question of whether the residence had been knowingly and properly placed into the trust by Melcher should have been tried by a jury, notwithstanding these issues were raised in an action for declaratory relief.

The constitutional provision for a jury trial grants that right only in actions based upon the common law of 1850, in the event the cause of action, or one essentially similar, existed. If the action is addressed to equity powers of the court, the matter is one for the trial court alone. (Dills v. Delira Corp. (1956) 145 Cal.App.2d 124, 128 [302 P.2d 397].) In order to determine whether an action for declaratory relief is equitable or legal, we must look behind the declaratory relief label to the gist of the action. (C & K Engineering Contractors v. Amber Steel Co. (1978) 23 Cal.3d 1, 9 [151 Cal.Rptr. 323, 587 P.2d 1136]; Veale v. Piercy (1962) 206 Cal.App.2d 557 [24 Cal.Rptr. 91]; Dills v. Delira Corp., supra, 145 Cal.App.2d at p. 128.)

Looking at the pleadings in this action, we find Strauss and Summerhays each sought to quiet title to the residence. Both the complaint and the cross-complaint allege the elements, of a quiet title action, 3 and the prayers request a determination of title.

A simple action to quiet title, where possession is not an issue, is equitable. {Veale v. Piercy, supra, 206 Cal.App.2d at p. 561; Dills v. Delira, supra, 145 Cal.App.2d at p. 130; see 2 Witkin, Cal. Procedure (2d ed. 1971) Actions, § 79, pp. 951-952.) Thus, the court properly determined the cross-actions were equitable and did not require a jury.

Strauss correctly points out Probate Code section 371 guarantees a right to jury trial on the issue of incompetency, fraud and undue influence in a *813 will contest. 4 She argues that right should apply to the same issues in an action regarding the validity of an inter vivos trust.

However, the right to jury in a will contest is purely a statutory right, not a right grounded in a common law action. (Estate of Beach (1975) 15 Cal.3d 623 [125 Cal.Rptr. 570, 542 P.2d 994].) The statutory right to a jury trial on the issues of incompetency, fraud and undue influence cannot be expanded to an action involving the validity of an inter vivos trust, as this is an equitable action. (Estate of Kreher (1951) 107 Cal.App.2d 831 [238 P.2d 150] (issue of undue influence in action to set aside joint tenancy agreements not entitled to jury trial).) Furthermore, a plain reading of Probate Code section 371 indicates it is limited to issues involving a will, not an inter vivos trust.

Strauss argues she was denied her statutory right to a jury trial in the will contest by the trial court’s decision to try the equitable issues first. However, where a disposition of equitable issues may obviate the necessity for a subsequent trial of legal issues, it is proper to try the equitable issues first. (Veale v.

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Bluebook (online)
157 Cal. App. 3d 806, 204 Cal. Rptr. 227, 1984 Cal. App. LEXIS 2248, Counsel Stack Legal Research, https://law.counselstack.com/opinion/strauss-v-summerhays-calctapp-1984.