In Re Conservatorship of John Bruce Wilson, Jr., M2021-00145-COA-R3-CV

A conservatorship was established for John Bruce Wilson, Jr. (the ward) in 2014; his brother Bennett G. S. Wilson (Scott) was appointed conservator.
The decedent (their father) executed a Will and a Separate Property Trust leaving John Jr. the largest share; the instruments had execution defects and were prepared on California forms.
The daughters sued in federal court, and the district court held Florida law applied and invalidated the Trust’s testamentary provisions, directing assets to pass by intestacy (equal shares).
John Jr.’s attorneys ad litem (appointed because Scott had a conflict) appealed to the Sixth Circuit; the appellate court ordered mediation and the attorneys ad litem negotiated a settlement.
The chancery court, invoking Tenn. Code Ann. § 34-1-121, authorized the attorneys ad litem to settle on John Jr.’s behalf and approved the mediated Settlement Agreement; Scott objected and appealed.
The Court of Appeals affirmed, holding the chancellor did not abuse discretion in approving the compromise and rejecting Scott’s other procedural challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the chancery court abused its discretion by approving the Settlement Agreement for the ward under § 34-1-121	Scott: settlement is not in John Jr.’s best interest; it reduces John Jr.’s share and conflicts with father’s intent	Daughters & attorneys ad litem: settlement removes litigation risk, gives certainty, gives John Jr. favorable cash/distribution terms, places proceeds in an irrevocable trust with independent trustee	Affirmed — no abuse of discretion; record supported best-interest finding and chancellor acted within § 34-1-121 authority
Whether the trial court was required to make written findings of fact and conclusions of law under Tenn. R. Civ. P. 52.01	Scott: Rule 52.01 required written findings/conclusions because the settlement disposes of estate interests	Daughters: 52.01 does not apply to decisions on motions; no separate findings were required	Held — no error; Rule 52.01 exempts motion decisions (except as to Rules 41.02 and 65.04(6)), so findings were not required
Whether appellees should receive damages for a frivolous appeal under Tenn. Code Ann. § 27-1-122	Daughters: Scott’s appeal was frivolous and taken for delay; request for damages and costs	Scott: (implicitly) appeal was meritorious	Held — discretionary denial; court declined to award damages for frivolous appeal

Lee Medical, Inc. v. Beecher, 312 S.W.3d 515 (Tenn. 2010) (defines abuse of discretion standard)
Eldridge v. Eldridge, 42 S.W.3d 82 (Tenn. 2001) (appellate review limits and abuse-of-discretion discussion)
Myint v. Allstate Ins. Co., 970 S.W.2d 920 (Tenn. 1998) (appellate standard — deference to trial court)
Chiozza v. Chiozza, 315 S.W.3d 482 (Tenn. Ct. App. 2009) (discretion to award damages for frivolous appeal discussed)
Industrial Development Bd. of City of Tullahoma v. Hancock, 901 S.W.2d 382 (Tenn. Ct. App. 1995) (defines frivolous appeal standard)
In re Conservatorship of Groves, 109 S.W.3d 317 (Tenn. Ct. App. 2003) (court authority to act in ward’s best interests in conservatorship)