Background
This interlocutory appeal arose from a dispute over the revocable trust of Ann Winslow. The trust was established in 1991 with Ann’s only child, Robert Winslow, as the sole beneficiary. In 1996, Ann married Ernest Poole, and in 1998, following a battle with cancer, she began amending her estate planning documents to include Ernest and his children from a prior marriage. Over the years, Ann made further changes. After 2010, she altered the beneficiary designations on her investment accounts and IRA to favor Ernest and her stepchildren, removing Robert entirely. In 2015, she executed a restated trust providing ten percent of her assets to her stepchildren. In 2019, Ernest was named co-trustee, and in 2021, her stepson Benjamin was appointed as an additional co-trustee. Ernest died later that year, and Robert later alleged that Benjamin engaged in self-dealing after his appointment.
Trial Court
In July 2022, Robert filed a petition asserting multiple claims. He alleged that Ernest and Benjamin exerted undue influence over Ann, who he claimed was susceptible due to her mental condition, and that she lacked testamentary capacity to change the trust. He further claimed that the Pooles had tortiously interfered with his inheritance by inducing Ann to amend the trust and change the beneficiaries of her investment accounts. Robert also alleged that Ernest and Benjamin, acting as Ann’s agents under her power of attorney, engaged in self-dealing, undue influence, and breaches of fiduciary duty. Finally, he sought a declaratory judgment that the trust amendments were invalid and that the trust had become irrevocable due to Ann’s alleged incompetence.
Court of Appeals
The Pooles challenged the court’s subject matter jurisdiction, arguing that such claims must be filed in probate court. The Court of Appeals disagreed, noting that probate jurisdiction is granted through the district court, and therefore the district court had authority to hear the case. On Robert’s claim of the Pooles self-dealing, the appellate court explained that trustees owe duties to current beneficiaries, not contingent ones. In this case, the corporate trustee, Iowa State Bank, was the proper party to pursue any self-dealing claims if appropriate.
The court applied similar reasoning to Robert’s remaining claims involving tortious interference, the legality of trust amendments, and the changes to investment account beneficiaries. Because Ann is still living, Robert has no present standing to sue. The trust expressly provides that its assets are to be used first and foremost for Ann’s care and may be fully depleted for that purpose. If the trust is exhausted during her lifetime, there would be nothing for Robert to inherit, meaning he has suffered no legal harm. The court also reaffirmed long-standing Iowa precedent holding that challenges to estate planning documents are generally litigated after the death of the person who created them to ensure efficient administration. For that reason, the court rejected Robert’s argument that alleged incapacity should trigger the trust to become irrevocable.
In the end, the Court of Appeals concluded that Robert could not bring his claims at this time. The decision underscores that without a direct, present injury, potential heirs typically cannot bring trust-related claims while the settlor is alive, and disputes over estate planning documents are better addressed after death.