Barefoot v. Jennings, 456 P.3d 447

Joan Lee Maynord created a revocable family trust; plaintiff Joan Mauri Barefoot was a beneficiary and successor trustee under earlier trust iterations.
Between 2013 and 2016 Maynord executed multiple amendments (17th–24th), and the final amendment before her death disinherited Barefoot and removed her as successor trustee, while increasing shares to other daughters (defendants).
After Maynord died in 2016, Barefoot filed a probate petition alleging the disinheriting amendments were invalid due to incompetence, undue influence, and fraud, and sought relief under Probate Code §17200.
Defendants moved to dismiss for lack of standing because Barefoot was not a named beneficiary in the trust’s final form; the trial court dismissed and the Court of Appeal affirmed.
The California Supreme Court granted review and reversed: it held that a person who alleges that disinheriting amendments were procured by incompetence, undue influence, or fraud — and who would be a beneficiary if those amendments are invalidated — has standing to petition the probate court under §17200.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a person eliminated as a named beneficiary by late amendments may petition probate court under Probate Code §17200 to challenge those amendments as invalid (incompetence, undue influence, fraud)	Barefoot argued she has standing because she was a beneficiary before the challenged amendments and would be a beneficiary if those amendments are voided	Defendants argued §17200 permits only currently named beneficiaries or trustees to petition, so Barefoot lacks standing because she was removed by the final amendments	The Court held that a person who pleads that disinheriting amendments are invalid and that invalidation would render them a beneficiary has standing to petition under §17200; the complaint’s pleaded facts must be taken as true at the pleading stage

Estate of Giraldin, 55 Cal.4th 1058 (2012) (discusses revocable trusts and settlor rights)
Brock v. Hall, 33 Cal.2d 885 (1949) (primary duty of court is to effectuate settlor intent)
Estate of Bissinger, 60 Cal.2d 756 (1964) (Probate Code intended to give probate court broad jurisdiction over trustee–beneficiary controversies)
Estate of Heggstad, 16 Cal.App.4th 943 (1993) (endorses expansive standing under §17200 and probate court discretion)
Warth v. Seldin, 422 U.S. 490 (1975) (standing analysis requires treating well-pleaded allegations as true)
Drake v. Pinkham, 217 Cal.App.4th 400 (2013) (permitting challenge under §17200 to amendments that disinherited petitioner)