Succession of Bonny Babin Maloney

CourtLouisiana Court of Appeal
DecidedOctober 4, 2023
Docket22-CA-571
StatusUnknown

This text of Succession of Bonny Babin Maloney (Succession of Bonny Babin Maloney) 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 Bonny Babin Maloney, (La. Ct. App. 2023).

Opinion

SUCCESSION OF BONNY BABIN MALONEY NO. 22-CA-571

FIFTH CIRCUIT

COURT OF APPEAL

STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 806-605, DIVISION "K" HONORABLE ELLEN SHIRER KOVACH, JUDGE PRESIDING

October 04, 2023

SUSAN M. CHEHARDY CHIEF JUDGE

Panel composed of Judges Susan M. Chehardy, Marc E. Johnson, and John J. Molaison, Jr.

AFFIRMED SMC MEJ JJM COUNSEL FOR PLAINTIFF/APPELLEE, CRAIG STEWART MALONEY, EXECUTOR OF THE SUCCESSION OF BONNY BABIN MALONEY Patrick S. McGoey Andrea V. Timpa McClain R. Schonekas

COUNSEL FOR PLAINTIFF/APPELLANT, KURT B. MALONEY Michael G. Calogero

COUNSEL FOR PLAINTIFF/APPELLEE-2ND APPELLANT, ROBERT S. MALONEY, JR. Jason R. Anders J. Scott Loeb Lauren F. Bartlett CHEHARDY, C.J.

Appellants, Robert S. Maloney, Jr. and Kurt Maloney, separately appeal the

trial court’s June 30, 2022 judgment, which granted a motion for partial summary

judgment in favor of their brother, Craig S. Maloney, in his capacity as the

executor of the succession of their mother, Bonny Babin Maloney, resulting in the

disinherison of appellants pursuant to a no-contest clause contained in their

deceased mother’s last will and testament. For the reasons discussed more fully

below, after de novo review, finding the trial court’s conclusion was legally correct

and supported by the undisputed facts, we affirm the trial court’s judgment.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

Bonny Babin (“Bonny”) married Robert S. Maloney, Sr. (“Robert Sr.”), and

of the marriage five children were born: Robert S. Maloney, Jr. (“Robert”), Kurt

Maloney (“Kurt”), Craig Maloney (“Craig”), Jeanie Maloney (deceased), and Julie

Maloney Wenck (“Julie”). During the course of their marriage, Robert Sr. and

Bonny successfully operated several businesses and invested in real estate,

accumulating significant wealth. The children eventually joined the family

business and worked together in various business enterprises thereby increasing the

family’s overall wealth.1 The family members continued in business together until

the demise of Robert Sr. on June 2, 2019.

Robert Sr. executed a notarial will (“Will”) on December 21, 2012, which

did not contain a “no contest clause.” During the year prior to his death, Robert Sr.

executed three codicils to his Will, each in notarial form, on June 15, 2018, August

28, 2018, and February 26, 2019, respectively.2 The first codicil increased the

property bequeathed to Bonny, including Robert Sr.’s one-half community interest

1 According to the record, while their parents were still alive, the family’s relationship with Robert Jr. and Kurt began to deteriorate due to their alleged theft from family businesses and because of their alleged failure to assist Robert Sr. in caring for Bonny following a cancer diagnosis. 2 A codicil is an addition or qualification to a will and is considered part of the will. Succession of Laborde, 17-1334 (La. App. 1 Cir. 5/31/18), 251 So.3d 461, 463.

22-CA-571 1 in the family home, and added a no-contest clause; the second codicil included

additional bequests to Bonny, slightly reducing the inheritances of Robert Jr. and

Kurt;3 and the third made changes to the successor executors, in the event Bonny

became unable to serve as executrix of his estate. Robert Sr. died on June 2, 2019.

As his surviving spouse, Bonny opened Robert Sr.’s succession on June 16, 2019,

in the Twenty-Fourth Judicial District Court, Parish of Jefferson, case number 796-

214, Succession of Robert S. Maloney, Sr., where the matter remains pending, and

was confirmed independent executrix. Bonny served as the independent executrix

of Robert Sr.’s estate until her death on May 4, 2020.

On August 7, 2019, prior to Bonny’s death, a judgment of partial possession

was rendered in Robert Sr.’s succession, that placed Bonny in possession of

numerous assets, including community property bequeathed to her in the first two

codicils of Robert Sr.’s Will. In particular, the trial court recognized Bonny as the

legatee in full ownership of Robert Sr.’s separate property,4 and placed Bonny in

possession Robert Sr.’s one-half interest in certain community assets, including the

family home at 185 Ridgewood Drive in Metairie, as well as various bank accounts

and accounts receivable. Consequently, on August 7, 2019, when the judgment of

partial possession was rendered in Robert Sr.’s succession, the family home on

Ridgewood Drive and other assets belonged solely to Bonny, in full ownership,

and formed a portion of her estate.

Approximately seven weeks later, on September 24, 2019, Bonny executed a

new Last Will and Testament (“Testament”) to include the assets she inherited

from Robert Sr. that now comprised a part of her estate. Execution of the

Testament was video recorded. Craig was named as independent executor of

3 The second codicil also left property located in Pearl River County, Mississippi, to Craig; however, this property had previously been transferred inter vivos to Craig on June 13, 2018. 4 Bonny was placed in possession in full ownership of Robert Sr.’s shares of stock in Maloney Trucking & Storage, Inc.

22-CA-571 2 Bonny’s estate. In her Testament, the family home is listed as a separate property

asset of Bonny valued at 1.1 million dollars, which Bonny bequeathed, in full

ownership, to her daughter, Julie. One quarter of Bonny’s residuary estate was

bequeathed to each of her four surviving children. Bonny’s new Testament also

included a no-contest clause, which specifically disinherits and revokes any legacy

to any legatee or heir who contests or challenges her Testament, or who seeks to

impair or invalidate any provision of her Testament, or “is otherwise engaged in a

controversy with or against the Executor of [Bonny’s] estate and which concerns

her estate.”

In the event of a violation, the no-contest clause mandates that:

… all legacies, bequests, and interests devolving as a result of [Bonny’s] death to any such person(s) who has/have done or attempted to do any of the acts described in sections (a) through (d) of this Article 13.1 (hereinafter the ‘Challenger,’ whether one or more) is hereby revoked; and said legacies, bequests, and interests shall not devolve to heirs of said Challenger, rather said revoked legacies, bequests, and interest shall become part of [Bonny’s] Residuary Estate …

Bonny died on May 4, 2020. On May 22, 2020, Craig Maloney was

confirmed as independent executor of his father’s succession, succeeding Bonny in

this position. On May 27, 2020, Bonny’s Testament was probated and Craig was

also confirmed as the independent executor of her succession. Bonny and Robert

Sr.’s successions remain open, and Craig remains the executor in each.

On August 7, 2020—exactly one year to the day after Bonny was placed in

possession as the full owner of the Ridgewood property and other assets, and three

months after her death—Robert Jr. and Kurt filed a petition in their father’s

succession to annul the three probated codicils to Robert Sr.’s original Will (on the

basis that Robert Sr. lacked testamentary capacity to understand or execute the

codicils), to vacate the August 7, 2019 judgment of partial possession, and for

22-CA-571 3 injunctive relief.5 The petition named Craig as a defendant, not only in his

capacity as the successor executor of Robert Sr.’s succession, but also in his

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