Chui v. Chui - Case Brief

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Chui v. Chui

Case Number: B306918

Court: Cal. Ct. App.

Date Filed: 2022-03-03

Case Brief – Chui v. Chui

Court: COURT OF APPEAL OF THE STATE OF CALIFORNIA
Date: 2025‑09‑03
Case Number: B306918
Disposition: The Court of Appeal affirmed the trial court’s orders enforcing the May 2018 settlement agreement, approving the January 2020 “second” guardian‑ad‑litem (GAL) agreement, appointing Jackson Chen as the minors’ GAL in all related probate matters, and denying Christine Chui’s motions to vacate the settlement, to remove Chen, and to obtain a new trial.

Holding

The court held that the trial court possessed jurisdiction to enforce the settlement agreement and to approve the second GAL agreement despite pending appeals, that the settlement and GAL agreements were valid and in the best interests of the minor beneficiaries, and that Christine Chui had waived any right to repudiate or object to those agreements because she had previously consented to the settlement and because the minors could only be represented by their appointed GAL.

Narrative

Lead

In a sprawling probate dispute that spanned more than a decade, the California Court of Appeal resolved a knot of contested settlement and guardian‑ad‑litem agreements involving a multigenerational family trust, allegations of elder abuse, and the competing interests of adult beneficiaries and two minor children. By affirming the trial court’s enforcement of a 2018 settlement and its approval of a 2020 “second” GAL agreement, the appellate decision clarifies the scope of a court’s authority to bind minor beneficiaries through a guardian, the effect of a party’s waiver of future claims, and the limited impact of parallel appeals on probate orders.

Procedural History

The litigation originated in the Los Angeles Superior Court (case BP154245) where Benjamin Chui, a co‑trustee of the family revocable trust, sued Christine Chui for alleged elder‑financial abuse of the trustor, King Wah Chui, and for misappropriation of trust assets. Over the ensuing years, multiple petitions were filed under Probate Code § 850 (elder abuse) and § 850.2 (trustee breach), as well as anti‑SLAPP motions under Code Civ. Proc. § 425.16. The parties—including the co‑trustees Margaret Chui Lee, the minor beneficiaries Jacqueline and Michael Chui, and other family members—engaged in a series of settlement negotiations that culminated in an oral agreement on May 14, 2018, recorded under Code Civ. Proc. § 664.6.

The settlement required Christine to waive all interests in Trust A, to deliver $3 million and certain jewelry, and to relinquish any future claims on behalf of the minors. In exchange, the minors would receive cash distributions and property interests, subject to approval by their guardian ad litem, Jackson Chen. The trial court subsequently enforced the settlement, denied Christine’s motion to vacate it, and later approved a “first” GAL agreement (August 2018) that reflected the settlement’s terms but was not signed by Christine.

Christine continued to challenge the settlement, filing motions to set aside the agreement, to remove Chen as GAL, and to obtain a new trial. The trial court denied these motions, granted Chen’s petition to remove Christine as GAL, and ultimately approved a revised “second” GAL agreement (January 16, 2020) that refined the distribution of assets and tax liabilities while preserving the settlement’s core benefits to the minors.

Both Christine and the minors appealed the trial court’s rulings. Separate appeals also lingered concerning an anti‑SLAPP decision (B288425) and an ILIT (irrevocable life‑insurance trust) judgment (B286548). The appellate panel was asked to determine whether the pending appeals barred the trial court from enforcing the settlement and approving the second GAL agreement, and whether the minors’ repudiations—filed without Chen’s participation—had any legal effect.

Facts

The family trust was created in 1988 by King Wah Chui and his wife Chi May Chui. After May’s death in 2004, the trust was split into three sub‑trusts (A, B, C). Trust C, an irrevocable entity, held several commercial and residential properties (Taylor, Paularino, Domingo, Derek, Calle Cristina). The trust’s residuary clause allocated 30 % each to Robert, Margaret, and Esther, with the remainder to other descendants. Amendments in 2004‑2005 added contingent bequests to Christine and the minor children.

King’s cognitive decline led to his resignation as trustee in 2011; Robert and Margaret became co‑trustees. Robert’s incapacity in 2013 prompted the court to appoint Benjamin (Robert’s son from his first marriage) as co‑trustee alongside Margaret. Robert died in 2013; King died in 2014, triggering the distribution provisions that placed the minors’ interests at the center of the dispute.

Esther, a sibling, alleged that Robert and Margaret had improperly delegated fiduciary duties to Christine, and later that both Christine and Robert had abused King to divert roughly $10 million of trust assets. Benjamin and Margaret counter‑claimed breach of fiduciary duty. The litigation expanded to include the minors’ estates, an ILIT, and related probate matters, resulting in at least eight “related” cases identified by the trial court.

Issues

  1. Jurisdiction and Effect of Pending Appeals: Did the existence of pending appeals in other probate matters deprive the trial court of authority to enforce the settlement and approve the second GAL agreement?
  2. Validity of the Settlement and GAL Agreements: Were the settlement and subsequent GAL agreements enforceable despite Christine’s claims of incapacity, unconscionability, and lack of a meeting of the minds?
  3. Authority to Repudiate: Could Christine, acting as a parent, guardian of the minors’ estates, and a trust beneficiary, unilaterally repudiate the settlement or GAL agreements without the minors’ GAL?
  4. Waiver of Future Claims: Did the parties’ waivers—particularly under Civil Code § 1542—effectively bar the minors from future accountings or appeals?

Holding and Reasoning

1. Jurisdiction Unaffected by Parallel Appeals
The court applied Probate Code § 1310(a), which stays the operation of a judgment only when the appeal directly challenges that judgment. The pending appeals (B286548, B288425, B301214) concerned separate orders—an anti‑SLAPP dismissal, an ILIT judgment, and a prior trial‑court order—none of which directly contested the settlement enforcement or the GAL approval. Accordingly, the trial court retained full authority to act on the settlement and GAL matters.

2. Settlement Enforceable; Waiver Effective
The appellate panel emphasized that the settlement was recorded under § 664.6, which permits enforcement of oral agreements entered in open court when the parties acknowledge understanding and consent. The trial court’s finding that all parties, except Christine (who left the courtroom after the oral recitation), affirmed their comprehension satisfied the statutory requirements. Moreover, the settlement expressly required that any claims on behalf of the minors could be brought only by their GAL, a condition Christine had previously accepted. By signing the settlement‑related documents and by the minors’ subsequent receipt of the $3 million distribution, the court concluded that the agreement was executed and that the parties had irrevocably waived future claims, including any right to demand further accountings.

3. No Authority for Unilateral Repudiation
The court held that a guardian ad litem is the exclusive representative of a minor in probate proceedings. Christine’s multiple “repudiation” filings—both as a parent and as a self‑appointed guardian—were deemed “improper and irrelevant” because they lacked the requisite authority. The minors’ own repudiations, filed without Chen’s involvement, were unverified and therefore legally ineffective. The appellate decision reinforced the principle that a minor’s interests cannot be litigated by a parent who has waived that role under a settlement.

4. Second GAL Agreement Valid and Superior to First
The second GAL agreement, executed after mediation, provided substantially better economic terms for the minors than the first GAL agreement, which the trial court had previously rejected. The agreement disentangled the minors’ assets from Benjamin’s holdings, allocated cash and property interests that covered estate‑tax liabilities, and included limited waivers of Civil Code § 1542 that were confined to trust‑administration matters. The court found no “negative effect” on the minors because the agreement eliminated any future financial interest they might have had in the trust, thereby satisfying the “best interests” standard that governs GAL approvals.

Impact and Unresolved Questions

  • Precedential Guidance on Settlement Enforcement – The decision underscores that a settlement recorded under § 664.6 is enforceable even when a party later alleges incapacity or unconscionability, provided the court finds a clear meeting of the minds at the time of recitation. Practitioners should ensure that all parties, especially guardians, are present and that the record reflects informed consent.

  • Scope of Guardian‑Ad‑Litem Authority – By holding that only the appointed GAL may assert or waive a minor’s rights, the court clarifies the limits of parental or self‑appointed representation in probate. Future disputes involving minors will likely hinge on the precise language of any settlement or GAL agreement and on whether the GAL has been properly appointed in all related cases.

  • Effect of Waivers on Future Accountings – The ruling validates broad waivers of the right to future accountings when they are part of a settlement that benefits the minor. However, the court limited the waiver to trust‑administration matters, preserving the court’s supervisory role over fiduciary conduct. Attorneys should draft waivers with explicit carve‑outs to avoid unintended forfeiture of oversight.

  • Interaction of Parallel Appeals – The opinion confirms that pending appeals do not automatically stay unrelated probate orders. Nonetheless, the court’s analysis left open the question of whether a future appeal directly challenging the settlement’s validity could stay its enforcement pending resolution.

Overall, Chui v. Chui provides a comprehensive roadmap for navigating complex, multi‑party probate settlements, especially where minors and guardian‑ad‑litem issues intersect with allegations of elder abuse and fiduciary breach.

Referenced Statutes and Doctrines

  • Probate Code §§ 850, 850.2, 850.3 – Elder abuse and fiduciary breach provisions.
  • Probate Code § 1310(a) – Effect of appeals on probate orders.
  • Code Civ. Proc. §§ 664.6 – Enforcement of oral settlement agreements entered in open court.
  • Code Civ. Proc. §§ 631.8 – Nonsuit/judgment after trial.
  • Code Civ. Proc. § 425.16 – Anti‑SLAPP statute.
  • Civil Code § 1542 – General release of unknown claims; limited waivers in the GAL agreements.

No specific case law was quoted in the opinion excerpt; the decision relies primarily on statutory interpretation and procedural precedent.