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Succession of Scurlock

Citations: 140 So. 3d 318; 13 La.App. 5 Cir. 960; 2014 La. App. LEXIS 1081; 2014 WL 1622380Docket: No. 13-CA-960

Court: Louisiana Court of Appeal; April 23, 2014; Louisiana; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by a son contesting the trial court's decision to uphold exceptions of prescription, thereby dismissing his petition to reopen his mother's succession. The appellant, who claimed entitlement to a forced share of the inheritance, argued that his claims were timely under the doctrine of contra non valentum due to his absentee status and mental health issues. Despite his assertions, the trial court found that the prescribed five-year period had elapsed since the probate of the will in 1991, and his petition filed in 2012 was untimely. The appellant further contended that he was unaware of the succession proceedings due to alleged fraudulent actions by the executors, but the court upheld the prescriptive period, finding no sufficient evidence for the suspension of prescription. The court also excluded his testimony and affidavit, determining they would not alter the decision on prescription. Consequently, his motion for a new trial was denied, and the trial court's judgment dismissing his petition was affirmed on appeal. The case underscores the necessity for timely action within prescribed periods in succession matters and the inapplicability of contra non valentum absent demonstrable impediments.

Legal Issues Addressed

Doctrine of Contra Non Valentum

Application: Tom argued that the prescriptive period was suspended due to his absentee status and incompetence, but the court found the doctrine inapplicable due to his lack of effort to assert his rights.

Reasoning: The court determined that Tom did not demonstrate efforts to assert his claims regarding forced heirship, and the doctrine of contra non valentum was deemed inapplicable.

Exclusion of Evidence

Application: The trial court excluded Tom's proposed testimony, finding no error as it was not prejudicial to a substantial right in the context of prescription exceptions.

Reasoning: The court found no error in excluding Tom's testimony or affidavit, as the facts surrounding the prescription exceptions were largely undisputed.

No Cause of Action

Application: The trial court deemed the exceptions of no cause of action moot after granting the exceptions of prescription.

Reasoning: The trial court granted the defendants' exceptions of prescription, dismissed Tom's petition to reopen Frances’ succession, and deemed the exceptions of no cause of action moot.

Prescription in Succession Proceedings

Application: The court applied the prescriptive period for reducing excessive donations and determined that Tom's petition to reopen the succession was filed outside this period.

Reasoning: Frances’ will was probated in December 1991, but Tom did not file his petition until July 2012, over 20 years later, thus exceeding the five-year period.