In Matter of the Estate of George, 265 P.3d 222

Decedent Deanna Bess George and Poland were married in May 1985; no children.
In 2008 Decedent transferred inherited property to the Deanna B. George Trust, appointing herself as trustee and Elaine Nalee as successor trustee, with explicit separate property language.
Decedent executed a pour-over will (2008) and a revocable inter vivos trust intended to disinherit Poland and affect his elective share.
In February 2009 Decedent initiated dissolution of marriage, which was later dismissed as moot after her death in November 2009.
Poland sought to probate a 2004 holographic will in probate court; Nalee (as personal representative and trustee) filed defenses and alternative petitions asserting the 2008 will and Trust; probate court admitted the 2008 documents and determined assets transferred to the Trust were not subject to probate.
In a separate civil action Poland claimed $125,000 against the Trust for work performed on a jointly owned building; the district court held the claim time-barred under Wyoming statute § 4-10-507 and dismissed with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Wyoming permit augmentation of the elective share by non-probate trust assets?	Poland argues elective share includes non-probate assets via augmentation.	George/estate argues elective share applies only to dispositions by will; no augmentation.	Wyoming rejects augmentation; elective share is limited to will dispositions.
Does probate jurisdiction extend to the Trust and its assets when a pour-over will and trust are involved?	Poland asserts probate court has broad jurisdiction over trust assets.	Estate argues probate jurisdiction does not reach the Trust; assets were not part of probate.	Probate court lacks jurisdiction over the Trust to adjudicate these claims.
Is Poland's creditor claim against the Trust timely under § 4-10-507?	Poland timely filed a creditor claim seeking $125,000.	Trust argues claim filed after notice period; claim time-barred.	Claim was time-barred; court lacked subject-matter jurisdiction over the Trust files.

First Nat'l Bank & Trust Co. v. Brimmer, 504 P.2d 1367 (Wyo. 1973) (trust interpretation; intention governs; four corners of document)
Briggs v. Wyoming Nat'l Bank, 836 P.2d 263 (Wyo. 1992) (elective share scope; will vs. inter vivos transfers)
In re Estate of Novakovich, 101 P.3d 931 (Wyo. 2004) (trusts and probate—timely claims; statutory framework)
Lohrie v. Estate, 950 P.2d 1030 (Wyo. 1997) (trust interpretation; intent governs; revocable trusts after death)