In Re: Estate of William Henry Fillhart No. 32-93-0409 ~ Appeal of: W.H. Coyle
2534 C.D. 2015
Pa. Commw. Ct.Oct 12, 2016Background
- Decedent William H. Fillhart died testate in 1993. His will left $3,000 to his grandson William H. Coyle (Objector) and the remainder to his daughter Elizabeth Jane Coyle (Daughter/Executrix), "her heirs and assigns."
- Daughter was appointed executrix in 1993 and later filed a First and Final Account on May 4, 2015; Objector filed objections six days later alleging fraud, incomplete accounting, conflicts of interest, and unaccounted property (including Maryland real estate and WV mineral rights).
- Auditor Jennifer Rega held a hearing (Objector participated by phone), found Objector had received the $3,000 legacy and therefore no remaining pecuniary interest in the estate, and concluded Objector lacked standing to challenge the First and Final Account.
- Auditor also determined the disputed Maryland properties passed to Decedent’s former wife by right of survivorship and were probated in her estate after her 1994 death, so they were not part of Decedent’s probate before the court.
- The trial court confirmed the Auditor’s Report (Sept. 9, 2015) and denied Objector’s motion to produce documents (Sept. 15, 2015), both on standing grounds; the Commonwealth Court affirmed and dismissed the appeal.
Issues
| Issue | Plaintiff's Argument (Coyle) | Defendant's Argument (Estate/Executrix/Trial Court) | Held |
|---|---|---|---|
| Standing to contest First and Final Account | Coyle contended the account was falsified/incomplete and raised fraud/conflict claims, seeking to challenge administration | Coyle received the $3,000 bequest and has no further pecuniary interest; only aggrieved parties with a pecuniary injury have standing | Held: Coyle lacked standing; objections dismissed |
| Motion for production of documents | Sought records regarding Maryland properties and WV mineral rights to support fraud/omission claims | Discovery was unnecessary given Coyle’s lack of standing and the Maryland property issues were not part of this probate | Held: Motion denied for lack of standing |
| Ownership/distribution of Maryland properties | Argued properties once owned by Decedent were improperly distributed or unaccounted for | Maryland properties passed by survivorship to Decedent’s former wife and were administered in her estate; not before this court | Held: Issues concerning Former Wife’s estate not before this court; not grounds to disturb this probate |
| Allegations of fraud, conflicts, due process violations | Alleged judicial/attorney misconduct, conflicts, and procedural unfairness warranting relief | Allegations were conclusory, unsupported by legal citation or record proof; insufficient to confer standing or reverse orders | Held: Allegations found unsupported; Court declined to act as counsel for appellant and affirmed dismissal |
Key Cases Cited
- Estate of Seasongood, 467 A.2d 857 (Pa. Super. 1983) (aggrievement/pecuniary interest required for standing to contest estate administration)
- In re Estate of Atlee, 178 A.2d 722 (Pa. 1962) (standing principles in probate matters)
- Wicker v. State Civil Serv. Comm’n, 460 A.2d 407 (Pa. Cmwlth. 1983) (appellate briefs that are rambling and unsupported preclude effective review)
- Commonwealth v. Spontarelli, 791 A.2d 1254 (Pa. Cmwlth. 2002) (unsupported, groundless allegations without analysis or authority do not warrant relief)