Barefoot v. Jennings

Case Number: S251574A

Court: Cal.

Date Filed: 2020-01-23

Case Brief – Barefoot v. Jennings

Court: Supreme Court of California
Date: 2020‑01‑23
Case Number: S251574
Disposition: Reversed the Court of Appeal’s dismissal 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 invalidate the amendment on grounds of incompetence, undue influence, or fraud.

Narrative

Lead – In a decision that broadens the reach of California’s probate jurisdiction, the Supreme Court rejected a narrow construction of Probate Code § 17200 and affirmed that a disinherited former beneficiary may challenge the validity of a trust amendment in probate court. The ruling clarifies the standing of parties whose interests were eliminated by a settlor’s late‑life changes, a question that has long divided California courts.

Procedural backdrop – The dispute began in Tuolumne County Superior Court, where Joan Mauri Barefoot, a daughter of the settlor Joan Lee Maynord, sought to set aside a series of amendments to the Maynord Family Trust that removed her as a beneficiary and successor trustee. After Maynord’s death on August 20, 2016, Barefoot filed a petition alleging that the amendments—executed between 2013 and 2016—were the product of the settlor’s incompetence, the defendants’ undue influence, and fraud. Defendants Jana Susan Jennings and Shana Wren moved to dismiss, invoking Probate Code §§ 17200 and 17202 and arguing that Barefoot, no longer a named beneficiary or trustee, lacked standing. The trial court agreed; the Court of Appeal affirmed.

Issues presented – Whether a person who was a beneficiary before a trust amendment—yet was excised by that amendment—may invoke Probate Code § 17200(a) to bring a petition challenging the amendment’s validity.

Supreme Court’s analysis – Justice Chin, writing for a unanimous Court, began by emphasizing the procedural rule that a demurrer or motion to dismiss on standing grounds must be decided on the pleadings as true. The Court therefore examined the statutory scheme as a whole rather than isolating § 17200(a).

Section 17200(a) authorizes “a trustee or beneficiary of a trust” to petition the court concerning the trust’s internal affairs. The Court read the term “beneficiary” in its ordinary statutory definition—Probate Code § 24(c)—as any person with a present or future interest, vested or contingent. Because Barefoot alleged that the amendments were invalid, she contended that she retained a present interest that would vest if the amendments were set aside. Under that reading, she qualifies as a “beneficiary” for purposes of § 17200.

The Court further relied on § 17200(b)(3), which expressly permits the court to determine “the validity of a trust provision.” An amendment is a trust provision; thus, a petition to invalidate an amendment falls squarely within the statutory grant of authority.

Citing the Court’s longstanding view that the Probate Code was intended to “broaden the jurisdiction of the probate court … to give that court jurisdiction over practically all controversies which might arise between the trustees and those claiming to be beneficiaries,” the opinion invoked Estate of Bissinger (1964) 60 Cal.2d 756 and Estate of Marre (1941) 18 Cal.2d 184. More recent appellate authority—Estate of Heggstad (1993) 16 Cal.App.4th 943 and Drake v. Pinkham (2013) 217 Cal.App.4th 400—supports an expansive reading of standing under § 17200, especially where the challenger’s claim is that the amendment itself is void.

The Court rejected the defendants’ “chaos” argument, noting that the statute does not open the floodgates to any “interested person” but limits standing to those whose alleged interests would be revived by a successful challenge. This distinction preserves the public policy embodied in §§ 21380 (presumption of fraud or undue influence in certain donative transfers) and § 17206, which gives the probate court broad equitable powers to resolve the matters presented.

Conclusion and impact – By reversing the appellate dismissal, the Court affirmed that a former beneficiary may seek judicial review of a trust amendment that allegedly stems from incompetence, undue influence, or fraud. The decision provides a clear procedural pathway for litigants to protect settlor intent and deters manipulative amendments made at the end of a settlor’s life.

Unresolved questions – The opinion expressly limited its holding to beneficiaries; it declined to address whether an heir who was never a beneficiary may challenge a trust amendment. Future litigation will likely explore that boundary, as well as the interplay between § 17200 and § 850 (which governs petitions concerning title and transfer of trust property).

Referenced Statutes and Doctrines

Probate Code §§ 17200(a), 17200(b)(3), 17202, 17206 – standing and petition authority; validity of trust provisions; court’s equitable powers.
Probate Code § 15800 – rights of the settlor while the trust remains revocable (relevant for distinguishing post‑mortem standing).
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 transfer of trust property (distinguished in this case).

Key Cases Cited