Succession of Audrey Mae Johnson Tyler

CourtLouisiana Court of Appeal
DecidedDecember 7, 2016
DocketCA-0016-0175
StatusUnknown

This text of Succession of Audrey Mae Johnson Tyler (Succession of Audrey Mae Johnson Tyler) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Succession of Audrey Mae Johnson Tyler, (La. Ct. App. 2016).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

16-175

SUCCESSION OF AUDREY MAE JOHNSON TYLER

**********

APPEAL FROM THE NINTH JUDICIAL DISTRICT COURT PARISH OF RAPIDES, NO. 39,913 HONORABLE THOMAS M. YEAGER, DISTRICT JUDGE

PHYLLIS M. KEATY JUDGE

Court composed of James T. Genovese, Phyllis M. Keaty, and D. Kent Savoie, Judges.

AFFIRMED AS AMENDED.

Larry B. Minton Attorney at Law 711 Washington Street Post Office Box 13320 Alexandria, Louisiana 71315-3320 (318) 487-0115 Counsel for Appellant: Deborah Marie Esteen Christopher K. LaCour Attorney at Law 3717 Government Street, Suite 11 Alexandria, Louisiana 71302 (318) 487-0210 Counsel for Appellee: Jernell Groves KEATY, Judge.

Appellant, Deborah Marie Esteen, appeals the trial court’s judgment in favor

of Appellee, Jernell Groves. For the following reasons, the trial court’s judgment

is affirmed with respect to the distribution of the funds on deposit in the registry of

the court and amended with respect to its allocation.

FACTS & PROCEDURAL HISTORY

This matter involves the Succession of Audrey Mae Johnson Tyler. Audrey

married Alvin Owen Tyler on June 9, 1956, in New Orleans. Four children were

born of this marriage: Gregory O. Tyler, Dwain A. Tyler, Leslie Tyler Williams,

and Melissa Tyler Chambers. This was the second marriage for both Audrey and

Alvin. Deborah is Audrey’s child of her first marriage, and Jernell is the child of

Alvin’s first marriage.

During their marriage, Alvin was a musician and earned income from music

royalties. The royalties, therefore, became community property. Following

Alvin’s death on April 3, 1998, Audrey lived in the family home in New Orleans

until 2005, when Hurricane Katrina destroyed it. She moved to Alexandria, and

the destroyed home was purchased by the Road Home Corporation under a grant.

In order to complete the transaction, Alvin’s succession was opened on

November 19, 2008. Audrey, Gregory, Dwain, Leslie, Melissa, and Jernell were

joint petitioners therein. The family home was listed as a community asset in

Alvin’s succession. In the Judgment of Possession, Audrey was recognized as

owner in her own right of an undivided one-half interest in the home. Alvin’s

children, Gregory, Dwain, Leslie, Melissa, and Jernell, were recognized as his

heirs. The Road Home Corporation purchased the property for $106,374.00.

Alvin’s one-half share of the proceeds was $53,187.00, which was divided equally

between his five children, i.e., $10,637.40 per child, after Audrey relinquished her

usufruct over Alvin’s share of the house proceeds. There was no evidence

indicating what Audrey did with her one-half share of the proceeds.

During their marriage, Audrey and Alvin maintained a joint bank account

with The Fidelity Homestead Association (joint Fidelity account). Audrey was

employed by the City of New Orleans during their marriage. When she retired, she

received a monthly pension from the New Orleans Municipal Employees

Retirement System as well as her Social Security benefits. She also received

Alvin’s music royalties. These funds were apparently commingled in various bank

accounts over time. The testimony in the record does not provide any explanation

as to what happened to those funds.

Audrey died on May 14, 2011. Audrey’s succession was opened on

March 22, 2012, in Rapides Parish, by attorney James Rex Fair, Jr., on behalf of

Leslie Tyler Williams as administratrix. A Judgment of Possession was signed on

March 23, 2012. A dispute arose regarding the proposed distributions of the assets,

prompting a “Petition To Deposit Succession Proceeds In Concursus Proceeding”

to be filed on June 29, 2012, on behalf of the heirs, which included Gregory,

Dwain, Leslie, Melissa, and Deborah. The petition was filed by attorney Jeffery H.

Thomas, who represented James Rex Fair, Jr., as the petitioner. The deposited

funds totaled $475,232.93. At issue herein is the division of the remaining

principal amount of $470,861.78.

On October 7, 2013, before any succession funds were distributed, Jernell

filed a petition to reopen Audrey’s succession. Therein, Jernell alleged that

2 unnamed assets listed in the concursus proceeding were not Audrey’s separate

assets, but remained community assets owned by Alvin and Audrey. She stated

that if the assets were community property, she should be included in the

distribution. Audrey’s succession was reopened pursuant to a consent judgment

signed on December 2, 2013. After the November 5, 2014 trial, the trial court

ruled in favor of Jernell, found that the funds on deposit in the trial court’s registry

were community property, and ordered payment from the funds in the following

percentages to: Jernell, 10%; Deborah, 10%; Gregory, 20%; Dwain, 20%; Leslie,

20%; and Melissa, 20%. A Judgment was signed on August 1, 2015, and Deborah

appealed.

On appeal, Deborah asserts the following assignments of error:

I. The trial court erred as a matter of law in failing to hold Jernell Groves, the petitioner in this case, to her burden of proving that the assets contained in the Succession of Audrey Mae Johnson Tyler were community property.

II. The trial court erred as a matter of law in holding that all of the assets contained in the Succession of Audrey Mae Johnson Tyler were presumed to be community property due to commingling, based only upon hearsay evidence, even though the community property regime had been terminated many years before.

DISCUSSION

I. Burden of Proof

In her first assignment of error, Deborah contends that the trial court erred as

a matter of law in failing to hold Jernell to her burden of proving that the assets

contained in Audrey’s succession were community property. She alleges that

Jernell, as the mover in this matter, had the burden of proving, by a preponderance

of the evidence, that certain assets contained in Audrey’s succession belonged to

the former community estate between Audrey and Alvin.

3 In opposition, Jernell concedes that she was the moving party. She contends,

however, that Deborah had the burden of proving the separate nature of the

property brought into the property regime.

In this case, Jernell argued in her petition to reopen Audrey’s succession that

some, if not all, of the property was community since it was earned during Audrey

and Alvin’s marriage. A consent judgment reopening Audrey’s succession was

signed by the trial court on December 2, 2013. The trial court held that Deborah

had the burden of proving at trial the separate nature of the property contained in

Audrey’s succession in order to overcome the community property presumption

pursuant to La.Civ.Code art. 2340.

In Louisiana, “[t]he legal regime of community property is terminated by the

death . . . of a spouse[.]” La.Civ.Code art. 2356. Therefore, upon Alvin’s death in

1998 and termination of community, Alvin’s undivided one-half interest in the

former community estate was transferred to his five children, subject to the legal

usufruct of Audrey. La.Civ.Code art. 890. In addition, at Alvin’s death, Audrey

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