Barefoot v. Jennings

Case Number: S251574

Court: Cal.

Date Filed: 2020-01-23

Case Brief – Barefoot v. Jennings

Court: California Supreme Court
Date: 2025-09-05
Case Number: S251574
Disposition: Reversed the judgment of the Court of Appeal and remanded for further proceedings consistent with this opinion.

Holding

The court held that a person who was a beneficiary of a revocable trust at the time an amendment was made—though later removed by that amendment—has standing under Probate Code § 17200 to petition the probate court to challenge the amendment’s validity on grounds of incompetence, undue influence, or fraud.

Narrative

When a settlor’s final amendments strip a child of any interest in a long‑standing family trust, the question of who may contest those changes can determine whether the settlor’s true intent survives. The California Supreme Court resolved that question in Barefoot v. Jennings, holding that a former beneficiary retains standing to challenge a disinheriting amendment when the challenger alleges the amendment was procured by incompetence, undue influence, or fraud.

Procedural backdrop
Joan Lee Maynord created the Maynord Family Trust in 1986 with her husband. After her husband’s death, Maynord became the sole trustor. Her three surviving daughters—Joan Mauri Barefoot (plaintiff), Jana Susan Jennings, and Shana Wren—were initially named beneficiaries, and Barefoot also served as successor trustee. Between 2013 and 2016, Maynord executed eight successive amendments (the 17th through 24th), the last of which—amended in August 2013, shortly before Maynord’s death—removed Barefoot’s share and her successor‑trustee role while substantially increasing Wren’s interest.

Following Maynord’s death on August 20, 2013, Barefoot filed a petition in Tuolumne County Superior Court asserting that the disinheriting amendments were invalid because Maynord was incompetent, the defendants exerted undue influence, and the amendments were fraudulent. The petition invoked Probate Code §§ 17200 and 17202, arguing that Barefoot, as a “person interested” in the estate and a former beneficiary, possessed standing. The trial court dismissed the petition, agreeing with the defendants that only a current trustee or beneficiary may invoke § 17200. The Court of Appeal affirmed, interpreting § 17200(a) to limit standing strictly to those presently named as beneficiaries or trustees.

Issue presented
Whether a person who was a beneficiary at the time an amendment was made—though later removed by that amendment—may invoke Probate Code § 17200 to challenge the amendment’s validity on the grounds of incompetence, undue influence, or fraud.

Supreme Court’s analysis
Justice Chin, writing for a unanimous Court, rejected the Court of Appeal’s narrow construction. The Court emphasized that a demurrer or motion to dismiss on standing grounds must be decided assuming the plaintiff’s factual allegations are true. If, under those assumptions, the plaintiff has a present or future interest in the trust, the statutory language of § 17200 must be read to confer standing.

Section 17200(a) authorizes “a trustee or beneficiary of a trust” to petition the court concerning the trust’s internal affairs. The Court noted that § 17200(b)(3) expressly allows the court to determine “the validity of a trust provision,” and that an amendment is a trust provision. Moreover, Probate Code § 24(c) defines a “beneficiary” as any person with a present or future interest, vested or contingent. Assuming Barefoot’s allegations are true, the contested amendments would restore her present interest, rendering her a beneficiary within the statutory meaning.

The Court turned to precedent affirming a broad reading of § 17200. Estate of Bissinger (1964) declared the Probate Code intended to give the probate court jurisdiction over “practically all controversies” between trustees and claimants. Estate of Heggstad (1993) and Drake v. Pinkham (2013) similarly endorsed an expansive view of standing, noting the court’s inherent power to resolve incidental issues necessary for trust administration. The Court also cited Conservatorship of Irvine (1995), which recognized the probate court’s authority to entertain petitions concerning the validity of trust amendments for both inter vivos and testamentary trusts.

Defendants warned that the broader interpretation would invite “chaos” by allowing individuals with no present interest to meddle in trust affairs. The Court dismissed that concern, clarifying that standing is limited to those whose well‑pleaded allegations show a present or future interest contingent on the amendment’s invalidity. In other words, a challenger must demonstrate that, but for the contested amendment, the plaintiff would be a beneficiary.

The Court further invoked Probate Code § 17206, which grants the probate court “any orders and take any other action necessary or proper” to dispose of matters presented in a petition, underscoring the court’s capacity to apply equitable principles despite its limited general equity jurisdiction. The public‑policy rationale—preventing fraud and undue influence in trust modifications—was reinforced by § 21380, which presumes certain donative transfers to be products of fraud or undue influence, and by Graham v. Lenzi (1995), which warned against insulating manipulators of settlors.

Conclusion and impact
By holding that a former beneficiary may sue to invalidate a disinheriting amendment when alleging incompetence, undue influence, or fraud, the Court restores a vital safeguard against abusive trust modifications. The decision clarifies that § 17200’s “beneficiary” language is not frozen at the time of filing but is responsive to the factual matrix of the petition. Practitioners must now assess standing not merely by current title but by the prospective interest that would arise if the challenged amendment were set aside.

The ruling also signals that probate courts will continue to serve as the appropriate forum for such challenges, preserving judicial economy and ensuring that the settlor’s true intent—free from coercion—prevails. Unresolved questions remain, however, regarding the standing of heirs who were never beneficiaries, a point the Court expressly left open for future adjudication.

Referenced Statutes and Doctrines

Probate Code §§ 17200, 17200(b)(3), 17202, 17206 – Petitioning the court; validity of trust provisions; dismissal authority; court’s remedial powers.
Probate Code § 24(c) – Definition of “beneficiary.”
Probate Code § 21380 – Presumption of fraud/undue influence in certain transfers.
Probate Code § 850 – “Interested person” petitions concerning title and transfer (distinguished).

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