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In re Masek Family Trust

Citation: 312 Neb. 94Docket: S-21-552

Court: Nebraska Supreme Court; July 29, 2022; Nebraska; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves a dispute over the administration and alleged breach of trust regarding a Family Trust established in 1993. Following the deaths of the original trustees, the trust became irrevocable, and successor trustees were appointed. The appellants, Mark and Dianne, were found liable for breach of trust by the Gage County Court, which issued a judgment against them. They challenged the court's jurisdiction and claimed insufficient process but were denied a new trial. On appeal, the Nebraska Supreme Court reversed the county court's decision, citing insufficient explanation for the breach of trust finding. The Supreme Court noted that while the appellants might have acted with knowledge of trust withdrawals, there was no clear evidence they assumed the role of trustees or participated in a breach as defined by the Nebraska Uniform Trust Code (NUTC). The Supreme Court remanded the case for further proceedings to evaluate the appellants' potential liability as de facto trustees or for participating in a breach of trust. The outcome emphasizes the necessity of clear findings and legal consistency in trust administration cases.

Legal Issues Addressed

Beneficiary Liability for Trust Losses

Application: A beneficiary is not personally liable for losses unless they participated in a breach of trust, requiring more than just knowledge or consent.

Reasoning: A beneficiary is generally not personally liable for a trust's losses unless they participated in a breach of trust, which requires more than just knowledge or consent to the breach.

De Facto Trusteeship and Liability

Application: The court may find a person liable as a de facto trustee if they assumed trustee duties under a color of right and exercised those duties.

Reasoning: A person may be deemed a de facto trustee and liable for breaches if they have assumed trustee duties under a color of right and exercised those duties.

Jurisdiction and Notice Requirements

Application: The appellants contested the county court's jurisdiction and notice procedures, but the court affirmed its jurisdiction, citing 20 years of involvement with the Family Trust.

Reasoning: The county court denied their motion, asserting proper notice and jurisdiction.

Participation in Breach of Trust

Application: The Restatement (Third) of Trusts suggests liability for a beneficiary requires participation, such as inducing misconduct with awareness it may be a breach.

Reasoning: The Restatement (Third) of Trusts suggests a beneficiary may be liable only if they participated in a breach, which includes inducing misconduct while aware it may constitute a breach.

Standard of Review for Trust Administration Matters

Application: The appellate court uses the standard of reviewing errors on the record unless the matter involves equity or questions of law, which are assessed de novo.

Reasoning: Trust administration matters are reviewed for errors on the record unless they involve equity or questions of law, which are assessed de novo.

Statutory Interpretation in Trust Law

Application: Statutory interpretation in trust law is a legal question determined independently by appellate courts.

Reasoning: Statutory interpretation is a legal question for which appellate courts independently determine conclusions.