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Townsend v. Rainier National Bank

Citations: 51 Wash. App. 19; 751 P.2d 1214Docket: Nos. 17514-9-I; 19229-9-I; 20279-1-I

Court: Court of Appeals of Washington; April 4, 1988; Washington; State Appellate Court

Narrative Opinion Summary

In this case, Charles F. Townsend sought to reform a deed and partition property held in a trust he shared with his late wife, Alice. The property was initially placed in trust with the Rainier National Bank to provide income for the couple, with their sons as remainder beneficiaries. Following Alice's death, Charles F. revoked his half of the trust and requested reformation of the deed due to a mistake in the property's description. The court ruled in his favor, amending the deed and confirming a sale of the property to Charles F. for $400,000, distributing the proceeds among the involved parties. The court upheld the trust's irrevocability concerning Alice's interest posthumously, ensuring its intent to support the beneficiaries. The beneficiaries appealed, contesting the distribution and the trust's management under RCW 7.52, which the court found inapplicable to trust management. The trustee's obligations to the trust terms were affirmed, and while the judgment was reversed regarding trustee fees, the trust's integrity was maintained, aligning with the settlor's original intent. The case also included proceedings in King County to clarify the trust's property holdings.

Legal Issues Addressed

Distribution of Trust Proceeds

Application: The court distributed the proceeds from a sale of the property, with specific allocations to Charles F., improvements, a life estate, and the remainder beneficiaries.

Reasoning: Proceeds were distributed as follows: $200,000 to Charles F. for his half interest, $56,250 for property improvements, $52,740.47 for a life estate, and $91,009.53 to the trust for the sons' remaindermen interest, totaling $400,000.

Irrevocability of Trust Post-Settlor's Death

Application: The court concluded that the trust became irrevocable concerning Alice's half interest after her death, aligning with the principle that trusts for beneficiary support cannot be terminated by consent.

Reasoning: The trust, structured to provide Charles F. with income and support during his life, was deemed irrevocable concerning Alice's half interest, aligning with the principle that trusts for beneficiary support cannot be terminated by consent and must remain active.

Partition Actions and Trust Management

Application: The court determined that RCW 7.52 does not govern the internal management of a trust estate, as the action was between Charles F. and the trust, not between him and his sons.

Reasoning: Charles F. claims that the court's procedure is mandated by RCW 7.52.300 and .340, which pertains to partition actions, but the action is between Charles F. and the trust, not between him and his sons.

Reformation of Trust Deeds

Application: The court found that a mistake warranted the reformation of the trust instrument to accurately reflect the property's description, allowing the correction of 'south 300 feet' in the deed.

Reasoning: The court found that a mistake warranted the reformation of the trust instrument to accurately reflect a description of 'south 300 feet.'

Trustee's Obligations Under Trust Deed

Application: The trustee was required to adhere to the terms of the trust, including the payment of all assessments and taxes on the properties.

Reasoning: The trustee was obligated to pay all assessments and taxes on the properties under the trust deed and the will executed simultaneously.