Autonomous Region of Narcotics Anon v. Narcotics Anon World Svcs
The court held that, because a revocable charitable trust may be enforced only by its settlor or by a party possessing a reversionary or property interest, a non-settlor such as the Autonomous Region of Narcotics Anonymous lacks standing to sue the trustee for breach of fiduciary duty and the charitable-trust "special-interest" standing doctrine does not extend to revocable trusts.
Date Filed: April 25, 2022
Case Name: Autonomous Region of Narcotics Anon v. Narcotics Anon World Svcs
Case Number: B309376
Court: California Court of Appeal, Second Appellate District, Division Eight
The Court holds that a party that is not the settlor of a revocable charitable trust lacks standing to enforce the trust’s fiduciary duties, and that the “special interest” standing doctrine for charitable trusts does not extend to revocable trusts. Accordingly, the Autonomous Region of Narcotics Anonymous cannot sue the trustee for breach of duty because it is neither the settlor nor a beneficiary with a reversionary or property interest. This decision narrows who may bring enforcement actions against revocable charitable trusts, preserving the settlor’s retained power to revoke and limiting judicial oversight to those expressly authorized by the trust instrument.
This case summary was prepared for educational purposes. For the authoritative version, please refer to the full opinion or the official California Courts website.