Succession of Robert S. Maloney, Sr.

Louisiana Court of Appeal·Decided November 9, 2022·No. 21-CA-618·Unknown

Opinion

SUCCESSION OF NO. 21-CA-618 ROBERT S. MALONEY, SR. FIFTH CIRCUIT

COURT OF APPEAL

STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT PARISH OF JEFFERSON, STATE OF LOUISIANA NO. 796-214, DIVISION "D" HONORABLE SCOTT U. SCHLEGEL, JUDGE PRESIDING

November 09, 2022

HANS J. LILJEBERG JUDGE

Panel composed of Judges Fredericka Homberg Wicker, Jude G. Gravois, and Hans J. Liljeberg

AFFIRMED HJL FHW JGG COUNSEL FOR PLAINTIFF/APPELLANT, ROBERT S. MALONEY, JR. J. Scott Loeb Lauren F. Bartlett Margaret M. Guidy Jason R. Anders

COUNSEL FOR DEFENDANT/APPELLEE, CRAIG STEWART MALONEY, IN HIS CAPACITY AS THE DULY CONFIRMED INDEPENDENT EXECUTOR OF THE SUCCESSION OF ROBERT S. MALONEY, SR., IN HIS CAPACITY AS THE DULY CONFIRMED INDEPENDENT EXECUTOR OF THE SUCCESSION OF BONNY BABIN MALONEY, AND IN HIS INDIVIDUAL CAPACITY McClain R. Schonekas Patrick S. McGoey Andrea V. Timpa LILJEBERG, J.

Appellant, Robert S. Maloney, Jr., seeks reversal of the trial court’s March

24, 2021 judgment dismissing his petition to annul three codicils to the will of his

father, Robert S. Maloney, Sr. Appellant requests that this Court grant him a new

trial because he contends the trial court abused its discretion by denying his oral

request for a 60-day continuance of the trial on his petition to annul, and by

denying his motion for new trial arising from the same issue. Appellee, Craig S.

Maloney, as executor to the succession of the parties’ father, Robert S. Maloney,

Sr., filed an answer to the appeal asserting that the trial court erred by denying his

request for attorney’s fees against appellant.

For reasons stated more fully below, we find the trial court did not abuse its

discretion by denying appellant’s motion to continue the trial and by denying

appellee’s request for attorney’s fees. Accordingly, we affirm the trial court’s

March 24, 2021 judgment.

FACTS AND PROCEDURAL BACKGROUND

Decedent, Robert S. Maloney, Sr., and Bonny Babin Maloney were married

for 60 years. They had five children, Bobby Jean Maloney, who predeceased

them, Robert S. Maloney, Jr., Kurt B. Maloney, Julie Ann Maloney Wenck and

Craig S. Maloney. Robert S. Maloney, Sr. died testate on June 2, 2019. On June

13, 2019, the decedent’s surviving spouse, Bonny Maloney, filed a petition to be

appointed independent executrix and to probate a notarial will executed by the

decedent on December 21, 2012, as well as three codicils to the will each in

notarial form, executed by the decedent on June 15, 2018, August 28, 2018, and

February 26, 2019. After Bonny Maloney died on May 4, 2020, appellee, Craig

Maloney, became the successor executor for his father’s succession.

21-CA-618 1 On August 7, 2020, appellant and Kurt Maloney1 filed a petition to annul the

three probated codicils, as well as a prior judgment of partial possession that

placed Bonny in possession of various assets. Appellant and Kurt claimed that the

codicils dramatically altered the distribution of assets in the will in favor of

appellee and Bonny Maloney. The petition explained that due to strokes the

decedent suffered in September 2012, his vision was impaired resulting in the

inability to read which worsened with age. The petition also alleged that at the

time the decedent executed the first codicil in June 2018, as well as the subsequent

codicils, the decedent was afflicted with the physical and mental effects of

cerebrovascular disease, including the inability to read. Appellant and Kurt

claimed that the codicils are absolutely null because 1) they did not comply with

La. C.C. art. 1579, requiring certain formalities when the testator is unable to read;

2) the decedent lacked testamentary capacity; 3) Bonny and Craig Maloney unduly

influenced the decedent; and 4) the decedent signed the will and codicils outside of

the presence of the notary and witnesses.

The petition to annul also requested the issuance of a temporary restraining

order (“TRO”), without notice to the executor, to prohibit the executor from

disposing of succession property. The trial court granted the TRO on August 12,

2020. On August 24, 2020, the appellee executor filed a motion to dissolve the

TRO and requested costs and attorney’s fees for the alleged wrongful issuance of

the TRO. On September 1, 2020, the trial court signed an order declaring the

motion to dissolve the TRO moot because the TRO dissolved as a matter of law.

On September 22, 2020, appellee filed an exception of no cause of action

urging that the petition to annul contained no facts to support a claim that the

codicils should be annulled for lack of the decedent’s mental capacity or undue

1 Kurt Maloney did not join in or file an appeal of the March 24, 2021 judgment dismissing the petition to annul the codicils.

21-CA-618 2 influence. Appellant and his brother, Kurt, did not file an opposition to the

exception of no cause of action. However, they did withdraw their request for a

preliminary injunction to prohibit the encumbrance, transfer or sale of succession

assets. On October 22, 2020, appellee filed a supplemental memorandum

requesting attorney’s fees with respect to the issuance of the TRO.

On October 26, 2020, the trial court held a hearing on the unopposed

exception of no cause of action and appellee’s request for attorney’s fees. The trial

court granted the exception of no cause of action and allowed appellant and Kurt

30 days to amend the petition to annul to add additional facts in support of their

claims of lack of mental capacity and undue influence. The trial court also

deferred appellee’s request for attorney’s fees with respect to the issuance of the

TRO until trial. On that same day, the trial court also conducted a pre-trial

conference, and the parties set a trial date on the petition to annul for March 1,

2021. On November 25, 2020, appellant and Kurt filed a first amended and

supplemental petition which added factual allegations regarding the decedent’s

alleged lack of mental capacity, but deleted allegations regarding their claim for

alleged undue influence, as well as their request for injunctive relief.

On December 17, 2020, appellee filed a motion for partial summary

judgment urging that appellant and Kurt did not have evidence to prove the

codicils were invalid due to the alleged failure to execute them in the presence of a

notary and two witnesses. Prior to the hearing on the summary judgment motion,

appellant and Kurt agreed to withdraw this claim. On February 18, 2021, the trial

court signed an order dismissing the claim with prejudice, leaving claims regarding

the failure to follow requisite formalities due to the decedent’s alleged inability to

read and alleged lack of testamentary capacity to execute the codicils as the

remaining issues for trial.

21-CA-618 3 On the day of trial, March 1, 2021, the parties agreed to attempt mediation,

and the trial court continued the trial for ten days until March 11, 2021. The

parties participated in mediation, and appellee contends that the parties reached a

settlement and his counsel drafted settlement agreements. Appellant contends, on

the other hand, that the parties did not engage in substantive settlement

negotiations. Instead, he claims that during this time period, he and Kurt learned

their counsel was not prepared to proceed to trial because they did not have an

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