Succession of Kathryn Andrews Lambert

CourtLouisiana Court of Appeal
DecidedNovember 7, 2007
DocketCA-0007-0630
StatusUnknown

This text of Succession of Kathryn Andrews Lambert (Succession of Kathryn Andrews Lambert) 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 Kathryn Andrews Lambert, (La. Ct. App. 2007).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

CA 07-630

SUCCESSION OF KATHRYN ANDREWS LAMBERT

**********

APPEAL FROM THE TENTH JUDICIAL DISTRICT COURT PARISH OF NATCHITOCHES, NO. 11849 HONORABLE ERIC ROGER HARRINGTON, DISTRICT JUDGE

BILLY HOWARD EZELL JUDGE

Court composed of Ulysses Gene Thibodeaux, Chief Judge, Sylvia R. Cooks, and Billy Howard Ezell, Judges.

AFFIRMED IN PART, AND REMANDED.

John Edward Fitz-Gerald Attorney at Law One Lakeshore Drive, Suite 1460 Lake Charles, LA 70629 Counsel for Appellant: Michael Glenn Lambert

Charles Raymond Whitehead, Jr. Whitehead Law Offices P. O. Box 697 Natchitoches, LA 71458-0697 (318) 352-6481 Counsel for Appellant: Julie Boudreaux Jeffrey Howerton Thomas Thomas & Thomas Law Firm P. O. Drawer 548 Natchitoches, LA 71458-0548 (318) 352-6455 Counsel for Appellee: Jerry Glenn Lambert

William Alan Pesnell The Pesnell Law Firm P. O. Box 1794 Shreveport, LA 71166-1794 (318) 226-5577 Counsel for Appellee: Jerry Glenn Lambert EZELL, JUDGE.

In this succession matter, Julie Lambert Boudreaux and Michael Lambert

appeal the decision of the trial court finding that their father retained a legal usufruct

over community funds bequeathed them by their deceased mother, Kathryn Lambert.

Their father, Jerry Lambert, also appeals the decision of the trial court, claiming that

the funds should not have been included in the succession or should now be his

separate property. For the following reasons, we affirm the decision of the trial court

in part, and remand.

Jerry and Kathryn Lambert were married and had two children, Julie and

Michael. During the marriage, Jerry worked at Texaco and accumulated a substantial

retirement pension. There is no dispute that the pension was a community asset. In

June of 1989, Jerry and Kathryn elected to receive a lump sum payment of

$320,851.76 from the pension in lieu of an annuity. This money was rolled over into

an IRA with Main Stay mutual funds. The record is devoid of any evidence as to the

pay status of the IRA at that time. In 1992, Kathryn executed a last will and

testament, leaving all her property to Julie and Michael, subject to a usufruct in favor

of Jerry until his death or remarriage. Kathryn died in May of 1994. At the time of

Kathryn’s death, the IRA had a value of $560,229.11.

After her death, but prior to the opening of Kathryn’s succession, Jerry rolled

the Main Stay funds over to yet another IRA, run by Edward D. Jones. When the

succession of Kathryn Lambert was opened in April of 1995, the detailed descriptive

list included the account as community property. A subsequent judgment of

possession recognized Julie and Michael as naked owners of Kathryn’s one-half

interest in the account, subject to the usufruct defined by Kathryn’s will.

1 Jerry remarried in 1997, prompting Julie and Michael to demand their mother’s

one-half interest in the account. Jerry responded by seeking to re-open the succession

and have the IRA removed from the list of community assets. After much legal

wrangling, the trial court ultimately decided that the IRA was derived from

community funds and was, therefore, a community asset to be included in the

succession. However, he found that La.R.S. 9:1426 applied, creating a legal usufruct

in favor of Jerry to run until his death, despite the terms of Kathryn’s will. From this

decision, all parties appeal.

Jerry asserts two assignments of error on appeal. He claims that the IRA

should have been a non-probate item and not a part of the succession, or that,

alternatively, it should have been classified as his separate property. Julie and

Michael assert three assignments of error that essentially amount to two: that the trial

court erred in applying La.R.S. 9:1426 rather than La.R.S. 9:2440 and 2441, thereby

creating a continuing usufruct, and that the trial court erred in failing to recognize

Jerry’s obligation to pay to Kathryn’s estate one-half the value of the Main Stay IRA.

We will address Jerry’s assignments of error first and will address them

together. In Smith v. Smith, 311 So.2d 514, 524 (La.App. 3 Cir.1974), writ denied,

313 So.2d 840 (La.1975)(citations omitted), we stated:

Property acquired during the existence of the community of acquets and gains is presumed to be community property. The burden of overcoming this presumption rests upon the party asserting the separate and paraphernal nature of the property. To overcome this heavy burden, the proof must be clear, positive and of a legally certain nature that the property for some reason did not become a part of the community.

Thus, Jerry bears the heavy burden of proving the IRA was not a community

property interest. The trial court correctly and succinctly addressed Jerry’s claims in

its reasons for judgment, noting:

2 The case cited by [Jerry], Boggs v. Boggs, 520 U.S. 833, 117 S.Ct. 1754 (1997), is not applicable to this case. In that case, the employee/husband withdrew the money from his pension plan and rolled it over into an IRA after his first wife died. The Supreme Court held that ERISA preempted the children’s Louisiana community property law rights in the IRA. ERISA mandates that retirees own pension plan benefits free of any community property rights of a spouse or child. However, in that case, the children sought a community property interest in benefits that were undistributed at the time of [their mother’s] death. In the present case, the pension was distributed and rolled over into an IRA while Mrs. Lambert was alive. This exact scenario was left open by the Boggs Court:

This case does not present the question whether ERISA would permit a non-participant spouse to obtain a devisable community property interest in benefits paid out during the existence of the community between the participant and that spouse.

Id. at 845 (emphasis added). . . .

We agree with the trial court’s analysis of this issue and find Boggs to be

distinguishable, as the Texaco ERISA retirement plan was emptied out during the

existence of the community. The Lambert’s account was accumulated as a result of

community labor, and was, therefore, a community asset when it was rolled over into

the Main Stay account. There is no question that community funds were used to open

the IRA. There, it remained a community asset. See Hannan v. Hannan, 99-842

(La.App. 1 Cir. 5/12/00), 761 So.2d 700, writ denied, 00-1723 (La. 9/29/00), 770

So.2d 349. Hence, we conclude that the community of acquets and gains owned a

sum of money equivalent to the value of the IRA at the time of decedent’s death.

Succession of McVay v. McVay, 476 So.2d 1070 (La.App. 3 Cir. 1985). Jerry’s

assignments of error are without merit, and the trial court’s decisions on these issues

are hereby affirmed.

Julie claims that the trial court erred in failing to recognize Jerry’s obligation

to pay to Kathryn’s estate one-half the value of the Main Stay IRA, should we find

the account to be Jerry’s separate property. Because we have found that the account

3 is, indeed, community property, this assignment of error need not be addressed. Julie

and Michael both claim that the trial court erred in applying La.R.S. 9:1426 to

continue the usufruct in favor of Jerry, rather than La.R.S. 9:2440 and 9:2441. We

also disagree with this assertion.

Louisiana Revised Statutes 9:1426 states:

A.

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Related

Boggs v. Boggs
520 U.S. 833 (Supreme Court, 1997)
Succession of McVay v. McVay
476 So. 2d 1070 (Louisiana Court of Appeal, 1985)
Hannan v. Hannan
761 So. 2d 700 (Louisiana Court of Appeal, 2000)
Smith v. Smith
311 So. 2d 514 (Louisiana Court of Appeal, 1975)

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