TERMINATION OF TRUSTS:
• Pursuant to trust instrument
• E.g. Income to J, remainder to S ? as per instrument, when J dies, trust ends
• Prop 112.052 – termination at event or period of time
• Revocation or revocable trust
• Restatement – default = irrevocable and must state revocable
• Texas is the opposite – default = revocable and must state irrevocable – see Prop 112.051
- Lots of people signing up trusts without much thought – Texas and CA protect the unwary
- Starting to change – presumption becoming revocable
• All trust agreements should designate revocable or irrevocable
• Barnette v. McNulty
- Dacey Trust – how to avoid probate with forms
- B sets up Dacey revocable trust, then divorce wife and makes will that leaves corpus to different person
- Nonprobate transfer – won’t go through will
- Trying to control property not subject to will
- M says B revoked trust when made will
- Court says oral revocation OK (fraud potential?!)
- Oral revocations – generally acceptable
• Real property: trust agreements, file deed putting in trustee’s name (revoke orally and world is mistaken as to owner)
• Fraud problems
• Texas rule prevents this
- Restatement requires “manifest intention to revoke in any way unless instrument mandates specific”
• Document – acts that are conclusive of revocation
• Non-exclusive list that leaves room for other acts
- Texas – Prop 112.051c – set up in written instrument then revocation must be in writing
- Will revoked because inconsistent
- Court says no case law because:
- Will is not effective during lifetime and revocable must be revoked during lifetime
- Depends on terms of revocable trust – if specified then must follow and most don’t contemplate will revocation
• Modification:
- Retain the right to revoke and MAY AMEND
- Don’t have to revoke and set up new (lesser included)
- Ineffective modification:
- Tosh
• Can’t just insert page
• Prevents fraud potential
- Must show definite intent, e.g sign page, etc.
• Document interpretation cases:
- Court – determining without knowing (crap shoot as to who is correct)
• Completion of Purpose:
• Frost v. Newton
- Trust continues during life of H, A, and B, terminating at death of last
- Trustee may terminate earlier if not have sufficient property ($465K) – inapplicable
- Good Clause – it eliminates fees for trust with insufficient funds
- A and B are alive – terminate trust?!
- Dissent:
- Two purposes:
• Income for H (dead so completed)
• Education of A and B’s children (done with school)
- Therefore trust is done! Purpose is completed regardless of what document says
- Done automatically on completion
- Majority:
- No termination because have to complete as to purpose being only X and Y (may have other non-expressed reasons)
• Especially in light of trust language that terminates at death
- HAPID (?!?) because difficult to know when this time is
- Prop 112.024 – must show all purposes have been fulfilled and that only those purposes exist
- Poorly drafted – termination date totally inconsistent with distribution clause
• Termination by Impossibility or Illegality
• Judge may terminate
• Termination by Consent
• 337 – all beneficiary are adult and competent – may terminate if not frustrating material purpose
• 338 – Settlor and beneficiary may agree
- Since settlor is alive, don’t have to look at material purpose, since can change mind
• Must have consent of all beneficiaries and can’t violate a material purpose (US “Claflin doctrine”):
- Fact that has more than one beneficiary is not material
- Spendthrift trust language is material
• In England, can do anything – testator intent is disregarded
- Claflin doctrine prevents this in the US
• Bayley
- Prop 123.002, 123.003
- Parens patriae – AG represents all charities so that charities don’t have to litigate
- Charity wins and trust terminated
• Hatch
- Self-settled trust
- Refuses to apply doctrine of worthier title
- Court says “to X and remainder to Y” means exactly that
- Prop 5.042a – also dismisses Rule in Shelley’s Case
- Court says can’t terminate trust because heirs (who are these people!? They’re determined at death!) have remainder
- Can appoint guardian ad litem, but they’re then arguing for settlor to give all because will get it all when settlor dies
• Power of appointment could take all benefits from remaindermen
• NY doesn’t require unborn consent (Restatement 3rd agrees)
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