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Colonial Bank & Trust Co. v. Stevens

Citation: 163 Conn. 612

Court: Supreme Court of Connecticut; June 26, 1972; Connecticut; State Supreme Court

Narrative Opinion Summary

The case involves a request by the executor and trustee of an estate for judicial guidance on interpreting the terms of a testamentary trust created from the estate's residue. The trust's language mandates specific annual disbursements to six beneficiaries until the corpus is depleted, but contains ambiguities regarding its termination and distribution, especially in the event of a beneficiary's death. The Superior Court was asked to resolve these ambiguities, but the record lacks sufficient factual details, such as the trust's corpus value, income, expenses, and whether income would unreasonably accumulate over the beneficiaries' lifetimes. Without these facts, the court cannot provide the necessary guidance and has remanded the case for additional fact-finding. The court's decision emphasizes the necessity for a complete factual record to resolve complex issues of trust administration and interpretation effectively.

Legal Issues Addressed

Ambiguity in Trust Language

Application: The court finds ambiguity in the trust language regarding the termination and distribution of the corpus, particularly in scenarios involving a child's death.

Reasoning: There are ambiguous provisions concerning the trust's termination and the distribution of its corpus, particularly in scenarios involving a child's death.

Interpretation of Testamentary Trusts

Application: The court is called upon to interpret the language of a testamentary trust concerning its termination and distribution provisions.

Reasoning: The plaintiff, acting as executor and trustee of George A. Stevens, Jr.'s estate, seeks guidance from the Superior Court regarding the interpretation of the testator’s will and the administration of a trust established from the estate's residue.

Judicial Review of Trustee's Beliefs

Application: The court is unable to assess the trustee's belief regarding future income exceeding payments due to insufficient factual information.

Reasoning: While the parties have discussed judicial views on income accumulation, the court cannot determine if the trustee's belief about future income exceeding payments is factually sound.

Sufficiency of Record for Judicial Guidance

Application: The court determines that the record lacks sufficient factual information to provide guidance on the trust's administration and remands the case for further fact-finding.

Reasoning: The court acknowledges the plaintiff's allegations as admitted but finds the record insufficient to answer the nine reserved questions.