Utah Supreme Court
Can ambiguous documents support summary judgment in trust disputes? Goodnow v. Sullivan Explained
Summary
Betty Goodnow sued to declare that her mother had removed Marie Sullivan as a successor trustee through a series of letters prior to her death. The trial court granted summary judgment for Goodnow based on the letters, finding they constituted amendments to the trust removing Sullivan as successor trustee.
Analysis
In Goodnow v. Sullivan, the Utah Supreme Court addressed whether ambiguous documents could establish a settlor’s intent to remove a successor trustee as a matter of law, ultimately reversing a trial court’s grant of summary judgment.
Background and Facts
Fern Morrison created an inter vivos trust naming her daughters Betty Goodnow and Marie Sullivan as successor trustees. Before her death, Morrison signed several letters, including an August 1998 letter stating she wanted to “assure that my daughter, Marie Sullivan, does not have control of my property after my death.” She also wrote to her bank removing Sullivan as a signatory and later directed an attorney to “change Marie M. Sullivan as trustee to Betty Goodnow.” Goodnow sued to declare these letters removed Sullivan as successor trustee.
Key Legal Issues
The central issue was whether Morrison’s letters constituted an amendment to the trust removing Sullivan as successor trustee, and whether this determination could be made as a matter of law on summary judgment.
Court’s Analysis and Holding
The Utah Supreme Court found that conflicting inferences could be drawn from the evidence. The August 6 letter did not specifically reference the trust agreement or use formal amendment language. Morrison’s subsequent request for a formal amendment raised questions about whether she intended the earlier letter as a trust modification. The court emphasized that when equally plausible contrary inferences may be drawn, summary judgment is inappropriate because genuine issues of material fact exist regarding the settlor’s intent.
Practice Implications
This decision reinforces that trust interpretation requires careful examination of the settlor’s intent. Practitioners should ensure trust amendments use clear, unambiguous language specifically referencing the trust document. When advising clients on trust modifications, formal amendment procedures should be followed rather than relying on informal correspondence that could create ambiguity about the settlor’s true intentions.
Case Details
Case Name
Goodnow v. Sullivan
Citation
2002 UT 21
Court
Utah Supreme Court
Case Number
No. 990805
Date Decided
February 26, 2002
Outcome
Reversed
Holding
A trial court cannot grant summary judgment when equally plausible contrary inferences may be drawn regarding the settlor’s intent to amend a trust agreement.
Standard of Review
Correctness for conclusions of law; facts viewed in light most favorable to losing party below
Practice Tip
When seeking to establish a settlor’s intent to amend a trust, ensure the evidence clearly demonstrates intent rather than relying on ambiguous documents that could support multiple inferences.
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