Succession of Barbara Ann Crow

CourtLouisiana Court of Appeal
DecidedMay 22, 2024
Docket55,608-CA
StatusPublished

This text of Succession of Barbara Ann Crow (Succession of Barbara Ann Crow) 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 Barbara Ann Crow, (La. Ct. App. 2024).

Opinion

Judgment rendered May 22, 2024. Application for rehearing may be filed within the delay allowed by Art. 2166, La. C.C.P.

No. 55,608-CA

COURT OF APPEAL SECOND CIRCUIT STATE OF LOUISIANA

*****

SUCCESSION OF BARBARA ANN CROW

Appealed from the Thirty-Ninth Judicial District Court for the Parish of Red River, Louisiana Trial Court No. 4155

Honorable Luke D. Mitchell, Judge

MIRAMON LAW, INC. Counsel for Appellant, By: Patricia N. Miramon Chase Alan Crow

KELLY & TOWNSEND, LLC Counsel for Appellee, By: William C. Townsend Tarkedria Hill

THOMAS LAW FIRM By: Jeffrey H. Thomas

Before PITMAN, STONE, and STEPHENS, JJ.

PITMAN, C.J., dissents with written reasons. STEPHENS, J.

This appeal arises from the 39th Judicial District, Parish of Red River,

the Honorable Luke Mitchell, Judge, presiding. Appellant, Chase Crow,

challenges the district court’s ruling granting partial possession to appellee,

Tarkedria Hill, of the usufruct granted to her in decedent’s will over her

residence and some of her oil, gas, and mineral interests. For the reasons

expressed herein, we affirm.

FACTS AND PROCEDURAL HISTORY

Decedent, Barbara Ann Crow, died testate on May 28, 2022. At the

time of her death, the decedent was domiciled in Red River Parish. She had

never married and had no children. Prior to her death, the decedent executed

a last will and testament on March 24, 2021. In the will, Ms. Crow left

Tarkedria Hill (“Ms. Hill”) a lifetime usufruct over the entirety of her estate.

The will provided in pertinent part:

I further declare that this usufruct shall extend to and shall include any and all royalties, bonuses, lease payments or other like payments attributable to (1) any lignite production and/or lignite leases on any property and (2) any oil, gas or other mineral leases which are in existences at the time of my death.

Subject to Ms. Hill’s usufruct, the decedent named her nephew, Chase Crow

(“Mr. Crow”), as naked owner. Ms. Hill was also named and appointed as

independent administrator.

Following Ms. Crow’s death, Ms. Hill filed a petition to probate the

will and for qualification as independent administrator on July 1, 2022. On

July 12, 2022, the district court declared the decedent’s last will and

testament to be in proper notarial form and admitted the will to be probated.

The court also appointed Ms. Hill as independent administrator, subject to

her compliance with the requirements of the law. Mr. Crow then filed a rule for security and accounting, as well as to remove Ms. Hill as administrator,

on August 1, 2022. In his rule, Mr. Crow requested that Ms. Hill be ordered

to file a detailed descriptive list of all assets owned by Ms. Crow at the time

of her death.

Ms. Hill filed a detailed descriptive list of the decedent’s assets on

November 17, 2022. On that same day, Ms. Hill also filed a petition for

partial possession of the decedent’s estate. In her petition, Ms. Hill

requested that she be placed in possession of the usufruct of the residence

and all movable property, contents, furniture and fixtures situated therein.

Ms. Hill also petitioned the court to place her in partial possession of the

following oil, gas, and mineral interests:

1. SWN Production Company, LLC, Owner No. 686939-1

2. Genesis Crude Oil L.P., Lease Number R 17723000, Lease Number R 18542900, Lease R 18653300

3. Jeems Bayou Production Corporation, Owner No. 6731

4. Fite Oil & Gas, Inc. under owner name “CrowB”

Ms. Hill included in her petition that Mr. Crow should be placed in partial

possession of his naked ownership in these assets.

On November 30, 2022, the district court ordered Ms. Hill to post

security in the form of a $300,000 bond on or before December 7, 2022.

Ms. Hill filed her bond on December 6, 2022. Mr. Crow filed a rule against

sureties and to have the security declared invalid on January 5, 2023. Mr.

Crow then filed an opposition to placing Ms. Hill in partial possession of her

rights as usufructuary to the residence and the enumerated oil, gas, and

mineral interests. In his opposition, Mr. Crow argued that Ms. Hill could

not force his acceptance of the succession, and that a judgment of possession

2 under La. C.C.P. art. 3372 would not be procedurally permissible due to Ms.

Hill petitioning the court on behalf of Mr. Crow.

During a hearing held on January 25, 2023, the district court declared

Ms. Hill’s surety bond insufficient and ordered her to post sufficient security

by January 30, 2023, or she would be removed as administratrix.1 Also at

the hearing, the district court heard arguments on Ms. Hill’s petition for

partial possession. Ms. Hill urged that the legislature never intended for all

legatees to petition for possession, especially when reading La. C.C.P. art.

3061(C) which states in pertinent part, “[a] judgment sending one or more

petitioners into possession under a testamentary usufruct or trust…”

Furthermore, Ms. Hill suggested that La. C.C.P. art. 3031’s language

specifying “all legatees” to join in the petition contrasts with the language

found in La. C.C.P. art. 3372, which simply states that “the legatees” may be

sent into possession upon the filing of a petition for possession prior to the

homologation of the final tableau of distribution.

In response to Ms. Hill’s arguments, Mr. Crow urged that he could not

be compelled to be placed in possession of his legacy under Ms. Hill’s

petition because he did not petition the court under La. C.C.P. art. 3372. He

further argued that the district court could not place Ms. Hill in possession of

her usufruct without also placing Mr. Crow in possession of his naked

ownership. Mr. Crow concluded his argument by noting that the situation in

the matter is not ripe for anybody to be placed in possession. At the

1 The district court removed Ms. Hill as independent administratrix on March 23, 2023, for failing to post sufficient security.

3 conclusion of the arguments, the court declared that it would take the

petition for partial possession under advisement.

On February 6, 2023, the district court granted in part and denied in

part Ms. Hill’s petition for partial possession. The court granted partial

possession to Ms. Hill and recognized her as the usufructuary, placing her in

possession of the residence as well as the oil, gas, and mineral leases. In its

reasons for judgment, the district court identified two issues in this case: 1)

whether Mr. Crow can be forced to be placed in possession of succession

assets when he did not join in the petition for partial possession, and 2)

whether Ms. Hill can be placed in partial possession of those assets

bequeathed to her without consent of the other legatees.

In dealing with the first issue, the district court declared that it agreed

with the First Circuit that the district court’s placing of all legatees into

possession, when not all legatees have joined in the petition for possession,

does not follow the procedure set forth in La. C.C.P. art. 3372. See, Matter

of Succession of Naquin, 18-0518 (La. App. 1 Cir. 11/5/18), 266 So. 3d 912.

As a result, the court denied Ms. Hill’s petition as it related to Mr. Crow. As

to the second issue, the court stated it was unable to find jurisprudence

directly on point but ultimately concluded that the following language in

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Delaney v. McCoy
152 So. 3d 1049 (Louisiana Court of Appeal, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Succession of Barbara Ann Crow, Counsel Stack Legal Research, https://law.counselstack.com/opinion/succession-of-barbara-ann-crow-lactapp-2024.