In Re Estate of Rhoda Crane, A-3739-22

Rhoda Crane died in July 2020, with her residence held in a revocable trust and her sister, Joyce, as a co-trustee; both are now deceased.
After various family disputes and related litigation, the court appointed David Repetto as administrator CTA of Rhoda's estate and trustee of her trust in January 2021.
Plaintiff Michael Crane—Joyce’s son and a beneficiary—requested a formal accounting from Repetto, alleging missing valuable personal property and insufficient information on the estate’s assets and their disposition.
Repetto contended he provided a comprehensive informal accounting through certifications and a detailed appraisal report, and denied the existence of missing property claimed by Michael.
The trial court denied Michael’s request for a formal accounting, concluding he had received sufficient information and had not substantiated his claims, then denied reconsideration.
Michael appealed, arguing statutory and rule-based entitlement to a formal accounting, and challenging the court’s factual and legal conclusions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to Formal Accounting	Entitled by statute and rule after a year; didn't get sufficient information	Accounting was discretionary and already satisfied by informal certification	Trial court abused discretion; formal accounting warranted
Sufficiency of Informal Accounting	Only partial/incomplete information provided; akin to inventory not accounting	Provided sufficient, detailed inventory; further accounting unnecessary	Informal accounting inadequate; formal accounting required
Fiduciary Duty/Disclosure	Repetto failed duty by withholding full information about trust administration	Plaintiff knows estate assets; status as debtor limits entitlement	Regardless of debtor status, beneficiary entitled to accounting
Timing and Prejudice	Ongoing litigation shouldn't bar right to accounting now	Timing inappropriate given litigation; accounting can come later	No prejudice to estate; accounting should not await case end

In re Est. of Hope, 390 N.J. Super. 533 (App. Div. 2007) (explains broad equitable powers and abuse of discretion review in probate)
Wolosoff v. CSI Liquidating Tr., 205 N.J. Super. 349 (App. Div. 1985) (affirms broad discretion of probate court)
Salitan v. Magnus, 28 N.J. 20 (1958) (outlines standard for appellate interference with discretionary trial court decisions)
United States ex rel. U.S. Dep't of Agric. v. Scurry, 193 N.J. 492 (2008) (abuse of discretion review standard explained)