Virginia Anne Gerace Benoist v. Jackson National Life Insurance Company, Norma Ford Gerace, and Mary Kathryn Gerace Carleton

CourtLouisiana Court of Appeal
DecidedNovember 15, 2022
Docket2022CA0292
StatusUnknown

This text of Virginia Anne Gerace Benoist v. Jackson National Life Insurance Company, Norma Ford Gerace, and Mary Kathryn Gerace Carleton (Virginia Anne Gerace Benoist v. Jackson National Life Insurance Company, Norma Ford Gerace, and Mary Kathryn Gerace Carleton) 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
Virginia Anne Gerace Benoist v. Jackson National Life Insurance Company, Norma Ford Gerace, and Mary Kathryn Gerace Carleton, (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2022 CA 0292

VIRGINIA ANN GERACE BENOIST

VERSUS

JACKSONJACKSON NATIONALNATIONAL LIFELIFE INSURANCEINSURANCE COMPANY,COMPANY, NORMANORMA FORDFORD GERACE,GERACE, ANDAND MARYMARY KATHRYNKATHRYN GERACEGERACE CARLETONCARLETON

DATEDATE OFJUDGMENT.*OFJUDGMENT.* NOVNOV 11 55 20222022

ONON APPEALAPPEAL FROMFROM THETHE NINETEENTHNINETEENTH JUDICIALJUDICIAL DISTRICTDISTRICT COURTCOURT PARISHPARISH OFOF EASTEAST BATONBATON ROUGE,ROUGE, STATESTATE OFOF LOUISIANALOUISIANA NUMBERNUMBER 710447,710447, SECTIONSECTION 2727

HONORABLEHONORABLE TRUDYTRUDY M.M. WHITE,WHITE, JUDGEJUDGE

JerryJerry F.F. PepperPepper CounselCounsel forfor PlaintiffPlaintiff - -AppellantAppellant BatonBaton Rouge,Rouge, LouisianaLouisiana VirginiaVirginia AnneAnne GeraceGerace BenoistBenoist

MichelleMichelle LorioLorio St.St. MartinMartin Counsel Counsel forfor DefendantDefendant - - Appellee Appellee DavidDavid Gregory Gregory KochKoch NormaNorma FordFord GeraceGerace

RileyRiley E.E. HuntingtonHuntington BatonBaton Rouge,Rouge, LouisianaLouisiana

DawnDawn D.D. BonnecazeBonnecaze CounselCounsel forfor DefendantDefendant - - AppelleeAppellee F.F. CharlesCharles MarionneauxMarionneaux MaryMary KatherynKatheryn GeraceGerace CarletonCarleton MelissaMelissa JadeJade AvantAvant ThomasThomas C.C. NaquinNaquin BatonBaton Rouge,Rouge, LouisianaLouisiana

BEFORE:BEFORE: THERIOT,THERIOT, CHUTZ,CHUTZ, ANDAND WOLFE,WOLFE, JJ.JJ.

Disposition:Disposition: AFFIRMED.AFFIRMED. CHUTZ, J.

Plaintiff-appellant, Virginia " Ginny" Anne Gerace Benoist, appeals the trial

court' s judgment, granting a motion to dismiss her action to review the acts of a

mandatary ( action to review) serving under a power of attorney executed by

principal, defendant -appellee, Norma F. Gerace. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Ginny instituted this action to review on August 9, 2021, naming her sister,

Mary Kathryn " Mary Kay" Gerace Carlton, and her 91 -year- old mother, Mrs.

Gerace, as defendants.' According to the allegations of Ginny' s petition, in 2019,

Ginny' s daughter, Mary Turner (Mrs. Gerace' s granddaughter), was named as Mrs.

Gerace' s sole mandatary pursuant to a duly recorded power of attorney executed in

conjunction with an extensive estate plan set up for Mrs. Gerace. In February 10,

2020, Mrs. Gerace executed a new power of attorney that revoked Mary Turner' s

authority and named Mary Kay as Mrs. Gerace' s sole mandatary. Another power

of attorney was executed by Mrs. Gerace on May 5, 2021 that revoked the

February 2020 power of attorney in favor of Mary Kay and returned mandatary

authority to Mary Turner and also to Paul Benoist, Ginny' s husband ( Mary

Turner' s father). On June 29, 2021, Mrs. Gerace revoked the May 5, 2021 power

of attorney and executed a new one in favor of Mary Kay. In her August 9, 2021

petition, Ginny claimed that Mary Kay has exercised " undue and oppressive

influence" over their mother, using Mrs. Gerace' s assets as Mary Kay' s own.

1 In addition to the allegations of this action to review, Ginny levied other claims against her sister, including one for the intentional interference with contractual rights. Ginny also named Jackson National Life Insurance ( Jackson National) as a defendant. According to Ginny' s petition, Jackson National issued an annuity to Mrs. Gerace wherein she and Mary Kay were named as irrevocable beneficiaries such that Ginny was a third -party beneficiary of a stipulation pour autrui, which endowed her with contractual rights and standing to assert a breach of contract, challenging a liquidation of the annuity by Mrs. Gerace in January 2020. Although Ginny avers that Mary Kay " caused" Mrs. Gerace' s divestment of the Jackson National annuity and raises many complaints about Mary Kay' s conduct in conjunction with the liquidation of the annuity, Ginny clearly alleges that Mary Kay' s actions were without proper authority, legal mandate, or direction from Mrs. Gerace and, therefore, are outside the ambit of the action to review claim before us in this appeal.

9 On October 1, 2021, Mrs. Gerace filed a motion to dismiss, seeking

dismissal from this litigation initiated by Ginny. After a hearing on October 28, 2021, the trial court granted the motion. A judgment was signed on November 12,

2021, dismissing Mrs. Gerace from the litigation and granting Mrs. Gerace' s

request for attorney fees. Ginny appeals.

ACTION TO REVIEW THE ACTS OF A MANDATARY

If a mandatary breaches his or her fiduciary obligations, Louisiana

contemplates two methods by which recourse may be sought: the direct action and

the action to review. Elizabeth R. Carter, Fiduciary Litigation in Louisiana:

Mandataries, Succession Representatives, and Trustees, 80 La. L. Rev. 661, 677

2020). The direct action refers to the traditional remedies available for mandatary

malfeasance. The action to review, however, grants various interested parties other

than the principal the right to bring an action during the life of the principal to

review the mandatary' s actions. Id. See also La. R.S. 9: 3851- 3856.

The chapter setting forth the provisions of an action to review was added by

Louisiana Acts 2014, No. 356, § 1, under the title " Powers of Attorney for the

Elderly — Action to Review the Acts of a Mandatary." It is an attempt by

Louisiana, like many other states, to protect the vulnerable elderly population from

abuse, particularly financial abuse, arising from fiduciary misconduct. See

Fiduciary Litigation in Louisiana: Mandataries, Succession Representatives,

and Trustees, 80 La. L. Rev at 664.

Enactment of the action to review helps address a recurring practical

problem: the gap between mandate and interdiction. A principal with a

significantly diminished mental or physical condition may not be able to terminate

the mandate and seek recourse against his mandatary through the direct action. The

same is true if the mandatary is abusing the principal. The action to review brings

3 the contract of mandate closer to interdiction in some circumstances. It allows a

party other than the mandatary to bring an action " on behalf of the principal to

review the acts of the principal' s mandatary" and to seek relief on the principal' s

behalf. Fiduciary Litigation in Louisiana: Mandataries, Succession

Representatives, and Trustees, 80 La. L. Rev at 680- 81. See La. R.S. 9: 3851

setting forth a list of persons who may petition a court on behalf of the principal to

review the acts of the principal' s mandatary and grant relief as authorized in La.

R.S. 9: 3851- 3856).

Motion to Dismiss:

The action to review includes a procedural mechanism allowing the

principal to dismiss a plaintiff s action. La. R.S. 9: 3852 provides:

A. If the principal files a motion to dismiss the action, the principal shall testify in person at the hearing on the motion or, with the agreement of the parties or for good cause shown, by visual remote technology or by deposition.

B. The court shall grant the principal' s motion to dismiss the action if it finds that the principal is able to comprehend generally the nature and consequences of the acts of the mandatary and that the

mandatary' s authority to act is not the result of fraud, duress, or undue influence.

Thus, the principal may oppose the action to review. But in so doing, the principal

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Bluebook (online)
Virginia Anne Gerace Benoist v. Jackson National Life Insurance Company, Norma Ford Gerace, and Mary Kathryn Gerace Carleton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/virginia-anne-gerace-benoist-v-jackson-national-life-insurance-company-lactapp-2022.