Tiedemann v. Tiedemann

2025 IL App (5th) 241010
CourtAppellate Court of Illinois
DecidedOctober 2, 2025
Docket5-24-1010
StatusPublished

This text of 2025 IL App (5th) 241010 (Tiedemann v. Tiedemann) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tiedemann v. Tiedemann, 2025 IL App (5th) 241010 (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (5th) 241010 Decision filed 10/02/25, corrected 10/03/25. The text of NO. 5-24-1010 this decision may be changed or corrected prior to the filing of a Petition for Rehearing or the IN THE disposition of the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

DEBRA A. TIEDEMANN, as Trustee of ) Appeal from the The Edward E. Tiedemann Declaration of ) Circuit Court of Trust, Dated January 30, 2014, ) Piatt County. ) Plaintiff-Appellant, ) ) v. ) No. 24-CH-2 ) BRENT E. TIEDEMANN and KEVIN A. TIEDEMANN, ) Honorable ) Dana C. Rhoades, Defendants-Appellees. ) Judge, presiding. ______________________________________________________________________________

PRESIDING JUSTICE McHANEY delivered the judgment of the court, with opinion. Justices Moore and Sholar concurred in the judgment and opinion.

OPINION

¶1 Edward E. Tiedemann (Settlor) executed the “Edward E. Tiedemann Declaration of Trust”

(Trust) on January 30, 2014. He was the initial trustee of the Trust, and he named his wife, Debra

A. Tiedemann (Debra) as the successor trustee of his Trust. The beneficiaries of the Trust were

Debra, and his two sons, Brent E. Tidemann and Kevin A. Tiedemann (defendants). In 2022, the

Settlor and Debra obtained a loan for $862,400 to purchase land in St. Clair County. The purchase

was secured by a mortgage agreement dated June 30, 2022. Following the Settler’s death on

September 7, 2023, ownership of the Belleville property passed to Debra as a joint tenant with

right of survivorship. Following the Settlor’s death, no payments were made on the loan, and the

financial institution sent a notice of default, stating its intent to foreclose if the default was not

1 remedied. Thereafter, Debra filed her petition with the trial court asking for “aid and direction”

pursuant to the Illinois Trust Code (Code) (760 ILCS 3/101 et seq. (West 2022)) and sought to use

trust assets to pay off the bank loan. The defendants responsively argued that Debra could not use

trust assets to pay off the loan, as doing so would be contrary to the Probate Act of 1975 (Act)

(755 ILCS 5/1-1 et seq. (West 2022)). The trial court entered its order finding in the defendants’

favor on August 26, 2024. Debra timely appealed from that order. For the following reasons, we

affirm.

¶2 I. Background

¶3 On January 30, 2014, the date that the Settlor executed his Trust, he also executed his final

will. The Trust included tracts of real estate described in an attached and incorporated schedule.

The two tracts of Trust real estate were in St. Clair County and were labeled as tract No. 1 and

tract No. 2. The Trust was also defined to include any other property later added by the Settlor,

together with the proceeds thereof. At an unspecified date, a third St. Clair County tract was

transferred into the Trust.

¶4 Article 10 of the Trust provides that upon the Settlor’s death:

“[Debra] shall pay from the Trust Estate, directly or through my personal representative,

without apportionment or reimbursement, all of my just debts, including the expenses of

my last illness and funeral, all expenses of administration of property wherever situated,

passing under my Will or this [Trust] or otherwise, and all estate inheritance, transfer and

succession taxes which become due by reason of my death ***.”

¶5 On June 30, 2022, the Settlor and First Federal Savings Bank of Mascoutah (Bank)

executed a promissory note and a mortgage for $862,400 to purchase the Rentchler Station Road

property in St. Clair County. The Settlor signed the promissory note and the Settlor and Debra

2 both signed the mortgage. The promissory note was secured by a mortgage on four properties in

St. Clair County. Three of the properties were within the Trust. The fourth property, the Rentchler

Station Road property was not transferred into the Trust before the Settlor died. The Settlor also

signed an assignment of rents to the four St. Clair County properties to the Bank “TO SECURE

(1) PAYMENT OF THE INDETEDNESS AND (2) PERFORMANCE OF ANY AND ALL

OBLIGATIONS OF BORROWER AND GRANTOR UNDER THE NOTE, THIS

ASSIGNMENT, AND THE RELATED DOCUMENTS.” The Bank had the sole discretion as to

application of the rents, but any rents received by the Bank that were not applied to the costs and

expenses the Bank incurred in connection with the properties would be applied to the loan.

¶6 The Rentchler Station Road property was titled in the Settlor and Debra’s joint tenancy

with right of survivorship. Upon the Settlor’s death on September 7, 2023, ownership of the

Rentchler Station Road property passed by operation of law to Debra through her interest as the

property’s joint tenant with right of survivorship. Upon the Settlor’s death, Debra also became the

trustee of the Trust.

¶7 The record does not indicate if Debra made any mortgage payments on the Rentchler

Station Road property loan after the Settlor’s death. However, in January 2024, the Bank sent its

notification that both the promissory note and the mortgage were in default, stating that the Bank

intended to pursue foreclosure on the four properties if the default was not remedied. The amount

of outstanding debt was then $858,476.08.

¶8 Debra’s petition asked the trial court for aid and direction pursuant to section 201 of the

Code (760 ILCS 3/201 (West 2022)). She stated that the Trust contained a provision directing her,

as trustee, to “pay from the Trust Estate *** all of my just debts.” Debra indicated that the only

outstanding debts were the outstanding balance on the Rentchler Station Road property note of

3 $858,476.08, and an outstanding balance on a tractor loan of $22,978.61. She stated that she could

avoid foreclosure by paying off the promissory note with assets held by the Trust. At the time she

filed her petition, the only assets in the Trust were the three properties, but she stated that based

upon the Settlor’s pour-over will, the Settlor’s other assets, excluding the Rentchler Station Road

property, would pour into the Trust after probate proceedings. She asked the trial court to provide

aid and direction on how she, as trustee, should proceed with the payment of the Settlor’s debts.

¶9 On July 3, 2024, the defendants filed their response to Debra’s petition. The defendants

agreed that Debra was a beneficiary of the Trust, particularly with respect to the marital domicile

shared as of Settlor’s death and that they were beneficiaries of the balance of the Trust, to be

distributed equally. They disputed Debra’s claim that the loan on the Rentchler Station Road

property should be satisfied by Trust assets. The defendants alleged that three of the four St. Clair

County properties were Trust assets, but the fourth property—the Rentchler Station Road property,

consisting of 61.6 acres—had been titled jointly with right of survivorship by the Settlor and Debra

alone. They argued that using Trust assets to pay the indebtedness on the property would be at the

defendants’ detriment and would unjustly enrich Debra. The defendants cited section 20-19 of the

Act (755 ILCS 5/20-19 (West 2022)) to support their argument.

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Bluebook (online)
2025 IL App (5th) 241010, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tiedemann-v-tiedemann-illappct-2025.