In Iowa, the general rule is that the executor of a decedent’s estate bears the burden of proof if the estate’s final report is challenged. However, once the executor offers evidence to support the executor’s decisions, a party challenging the final report will have a difficult time prevailing. In any event, a party challenging estate administration must have standing to sue the executor. Generally, that means the challenger must be a person or entity specifically named in the decedent’s will or trust.
In this case, the decedent’s will gave the plaintiff, an unrelated former employee of the decedent, a $10,000 gift. The decedent’s will also created a residuary trust, but the trust failed to name a beneficiary. As a result, the executor’s position was that the residue of the decedent’s estate (the property remaining in the estate after specific bequests are allocated) passed under Iowa intestacy law. That meant that the residue would pass to the decedent’s relatives. The plaintiff received a copy of the executor’s final report for the estate and application to close the estate, learned that the trust had failed for lack of a beneficiary, and claimed that he should be named the beneficiary of the trust even though he wasn’t named as a beneficiary. The plaintiff sued to fire the executor and have a hearing to determine the trust’s beneficiary. To support his position that he should be named the trust’s beneficiary, the plaintiff offered a handwritten note of the decedent that stated the decedent “had financial plans” for the plaintiff that he had not shared with anyone else. The executor moved to dismiss the plaintiff’s claims, and the trial court held that the employee’s objections were untimely and that he lacked standing to challenge the executor’s decision because the trust failed to name the plaintiff as a beneficiary. The appellate court upheld the trial court’s decision. In re Estate of Raymon, No. 8-558/07-1579 (Iowa Ct. App. Aug. 13, 2008).