In re Estate of William J. Hannifin
311 P.3d 1016
| Utah | 2013Background
- Hannifin died intestate with no spouse or biological descendants; Nakai sought to inherit as Hannifin's equitably adopted child.
- district court found Nakai entitled to inherit under equitable adoption after a bench trial.
- Hill and other relatives challenged Nakai’s status, arguing Probate Code preempts common-law equitable adoption.
- Majority holds Probate Code preempts equitable adoption, displacing dual-succession rights and requiring intestate distribution per statute.
- Court finds Nakai cannot qualify as a 'child' or 'parent' under the Probate Code; Hill and relatives are potential takers under the Code.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the Probate Code preempt equitable adoption? | Hill argues Code displaces Williams' Estates. | Nakai argues equitable adoption remains valid alongside Code. | Yes; equitable adoption is preempted by the Probate Code. |
| Can equitable adoption coexist with the Code's intestate scheme? | Equitable adoption supplements, not conflicts with, the Code. | Coexistence is impossible due to dual-succession prohibition. | No coexistence; the Code governs intestate succession to statutory heirs. |
| Does the Code’s definition of 'child' and 'parent' foreclose equitable adoption? | Definitions do not foreclose equitable adoption; equity can supplement. | Definitions foreclose non-statutory equal inheritance via equitable adoption. | Definitions foreclose equitable adoption as to intestate succession. |
| Is there any room for supplementary equitable principles under the Code? | Equity should be allowed to achieve just outcomes. | Code aims for predictability and efficiency; equity must yield. | Equity must yield; no statutory room to supplement. |
Key Cases Cited
- In re Williams' Estates, 348 P.2d 683 (Utah 1960) (recognizes equitable adoption as a remedy)
- In re Adoption of A.B., 245 P.3d 711 (Utah 2010) (preemption analysis framework for conflicts)
- In re Estate of Christensen, 655 P.2d 646 (Utah 1982) (statutory definitions and preemption implications)
- Daniels v. Gamma W. Brachytherapy, LLC, 221 P.3d 256 (Utah 2009) (statute preempts common law by comprehensive addressing of a field)
- In re Benner's Estate, 166 P.2d 257 (Utah 1946) (dual inheritance under common law prior to Code)
- In re Estate of Pepper, 711 P.2d 261 (Utah 1985) (statutory supplementation of probate matters permitted)