Riverside County Public Guardian v. Snukst
The court held that, pursuant to Welfare and Institutions Code § 14009.5 and the federal Medicaid estate-recovery rules, assets placed in a revocable inter- vivos (.
Date Filed: January 10, 2022
Case Name: Riverside County Public Guardian v. Snukst
Case Number: E074949
Court: California Court of Appeal, Fourth Appellate District, Division Two
The Court decides that, under Welfare and Institutions Code §\u202f14009.5 and the federal Medicaid estate‑recovery rules, assets placed in a revocable inter‑ vivos (living) trust are treated as part of the decedent’s probate estate and must be used to satisfy a Medi‑Cal reimbursement claim before any distribution to the trust’s beneficiary. Accordingly, the appellate court reverses the probate court’s order approving the trust’s final accounting and remands for the department to be paid from the trust assets. This holding confirms that revocable trusts do not shield a Medicaid recipient’s property from post‑mortem estate‑recovery, a critical rule for probate and Medicaid‑planning practitioners in California.
This case summary was prepared for educational purposes. For the authoritative version, please refer to the full opinion or the official California Courts website.