In Re Estate of Ardell Hamilton Trigg
368 S.W.3d 483
| Tenn. | 2012Background
- Ardell H. Trigg died in 2006; her probate was in Putnam County; will left real property to Susan and Mark Shaw.
- TennCare filed a claim against the estate for nursing-home and long-term care costs incurred during the decedent’s life.
- Shaw, as personal representative, filed an exception to TennCare’s claim; probate court overruled the exception.
- Estate appealed to the Circuit Court for Putnam County; circuit court held the real property at issue was not part of the probate estate and remanded for further assets.
- TennCare appealed to the Court of Appeals; Court of Appeals found lack of circuit court subject-matter jurisdiction and remanded to probate court; Tennessee Supreme Court granted permission to address jurisdiction and whether real property is subject to TennCare claims.
- Supreme Court held that the circuit court lacked jurisdiction over the estate’s appeal and that real property owned by the decedent at death is subject to TennCare reimbursement under federal and Tennessee law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Circuit court jurisdiction to hear appeal from probate decision | Estate: §30-2-609 grants circuit court review | TennCare: Court of Appeals has jurisdiction for probate-claims appeals | Circuit court lacked jurisdiction; appeal proper to Court of Appeals |
| Whether real property owned at death can satisfy TennCare claims | Estate argues real property is not part of probate estate | TennCare: estate includes real property that can be used to pay debts | Real property is within the scope of TennCare reimbursement; it may be used to satisfy the claim |
| Definition of estate under Medicaid recovery provisions | Estate limited to personal property | Estate includes real property and other assets subject to debts | Estate includes real property and other assets capable of satisfying debts, including TennCare |
| interplay of federal and state probate/refinance statutes | State law controls probate boundaries; expanded federal definition not enacted | Federal law defines estate for Medicaid recovery; state may need expansion | Federal and state law permit TennCare to reach assets to reimburse benefits; remand for further probate proceedings consistent with ruling |
Key Cases Cited
- Commerce Union Bank v. Gillespie, 178 Tenn. 179 (1940) (appeals from county court judgments regarding claims against estates direct to appellate courts)
- Walker v. Gambill, 181 Tenn. 38 (1944) (where appeals from probate proceedings depend on the nature of the lower court proceeding)
- In re Estate of White, 77 S.W.3d 765 (2001) (appeals from probate judgments governed by 16-16-201(c) for certain counties)
- Tenn. Trust Co. v. Grimes, 179 Tenn. 567 (1943) (broad interpretation of 'estate' in will contexts)
- Commerce Union Bank v. Gillespie, 178 Tenn. 179 (1940) (appeals from county court judgments regarding claims against estates)