Beckwith v. Dahl
205 Cal. App. 4th 1039
| Cal. Ct. App. | 2012Background
- Beckwith and MacGinnis were in a long-term relationship; MacGinnis had no surviving immediate family besides Dahl.
- MacGinnis showed Beckwith a will proposing equal division between Beckwith and Dahl, but it was never signed or printed.
- In May 2009, MacGinnis asked Beckwith to locate the will; Beckwith instead drafted a new will for signing the next day.
- Beckwith informed Dahl of the new will and Dahl advised delaying signing and suggested a trust; Beckwith did not present the will.
- MacGinnis died intestate on June 2, 2009; Dahl opened probate and was named administrator; Beckwith was found to lack standing.
- Beckwith filed a civil action alleging intentional interference with expectancy of inheritance (IIEI), deceit by false promise, and negligence; demurrer was sustained without leave to amend.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Should California recognize IIEI as a tort? | Beckwith: recognition necessary to protect injured heirs. | Dahl: CA should not adopt IIEI; probate remedies exist. | California should recognize IIEI with limitations. |
| Can Beckwith state a valid IIEI claim here? | Beckwith alleges intentional interference by Dahl with testator’s actions. | Dahl: no independently tortious conduct directed at MacGinnis; insufficient facts. | IIEI claim improper at this stage; need amendment to cure defects. |
| Is Beckwith’s promissory fraud claim sufficiently pled? | Beckwith asserts Dahl promised trust documents to be prepared for MacGinnis to sign. | Dahl: statements vague; no intent to perform. | Promissory fraud adequately pled with particularity; reversal as to this claim. |
| Are damages and causation properly alleged for the fraud claim? | Beckwith relied on the promise and was harmed by not receiving half the estate. | Dahl: damages may be speculative or unrelated to fraud. | Damages and causation adequately alleged; supports fraud claim viability. |
Key Cases Cited
- Hagen v. Hickenbottom, 41 Cal.App.4th 168 (Cal. Ct. App. 1995) (first CA discussion of IIEI viability)
- Munn v. Briggs, 185 Cal.App.4th 578 (Cal. Ct. App. 2010) (CA adopts IIEI with probate remedy limitation)
- Temple Community Hospital v. Superior Court, 20 Cal.4th 464 (Cal. 1999) (tort recognition balancing policy and remedies)
- Cedars-Sinai Medical Center v. Superior Court, 18 Cal.4th 1 (Cal. 1998) (spoliation tort—policy considerations in recognition)
- Youst v. Longo, 43 Cal.3d 64 (Cal. 1987) (nonbusiness expectancies and interference tort boundaries)
- Blank v. Kirwan, 39 Cal.3d 311 (Cal. 1985) (nonbusiness expectancies may be protected where entitled to relief)
- Mazur v. Building Permit Consultants, Inc., 122 Cal.App.4th 1400 (Cal. Ct. App. 2004) (damages causation in fraud claims and reliance proof standards)
- Lazar v. Superior Court, 12 Cal.4th 631 (Cal. 1996) (elements of deceit; knowledge of falsity and intent)
- Goehring v. Chapman University, 121 Cal.App.4th 353 (Cal. Ct. App. 2004) (fraud elements and justifiable reliance standards)
- Patrick v. Alacer Corp., 167 Cal.App.4th 995 (Cal. Ct. App. 2008) (fraud damages and consequential damages discussed)