Irwin Shorr, as beneficiary of the Trust of Anna H. Blankstein v. Herbert Harris, as Trustee of the Trust of Anna H. Blankstein, 248 A.3d 633

In 1991 Anna H. Blankstein executed a revocable inter vivos trust and a pour‑over will; trustees were Blankstein, Herbert Harris (her attorney), and Sophie Garelick. The trust provided income to Blankstein during her life and specific bequests at death.
Blankstein amended the trust several times (last in 2003) and died in 2011; specific bequests (including $2,000 to Irwin Shorr) were distributed but Shorr requested a full accounting on March 4, 2011; Harris refused.
Shorr was later appointed administrator of Blankstein’s estate (Dec. 6, 2011) and sought trust documents and records via subpoena and litigation; Harris moved to quash and later sued in Superior Court for an accounting under the Rhode Island Uniform Custodial Trust Act (RIUCTA).
Harris moved for summary judgment arguing the trust is not a custodial trust under RIUCTA; after in camera review and hearings the trial justice granted summary judgment for Harris, finding the trust did not meet RIUCTA’s creation requirements and that Shorr lacked standing as estate administrator.
The Supreme Court affirmed: the trust was not a custodial trust and Shorr, as administrator, lacked authority to demand an accounting of assets that passed into the inter vivos trust via the pour‑over will.

Issue	Plaintiff's Argument (Shorr)	Defendant's Argument (Harris)	Held
Whether the trust is a custodial trust under RIUCTA	Trust contains many features like a custodial trust; that suffices	Trust does not name a custodial trustee and was for settlor’s benefit during her life	Not a custodial trust — RIUCTA’s statutory creation requirements not met
Whether a beneficiary may obtain an accounting under RIUCTA	As a beneficiary (sum‑certain), Shorr is entitled to petition for an accounting	No custodial trust exists, so RIUCTA does not apply	RIUCTA does not apply because trust is not custodial; no statutory accounting right under RIUCTA
Whether Shorr, as administrator of the estate, has standing to demand an accounting	As administrator, Shorr “steps into the shoes” of Blankstein and can obtain reports due to settlor	Assets passed to the inter vivos trust via pour‑over will and therefore are not part of probate estate	Shorr lacks standing as administrator to compel an accounting of trust property that became trust assets via pour‑over will
Whether genuine factual disputes exist about trustee compliance/consulting cotrustee	There remain factual disputes whether Harris consulted cotrustee or complied with trust terms	No material factual dispute; legal status of trust disposes of claim	No genuine issue of material fact controlling entitlement to relief; legal determination dispositive

Miller v. Saunders, 80 A.3d 44 (R.I. 2013) (interpreting RIUCTA and explaining that statutory language need not be verbatim but custodial‑trust creation elements must appear)
Filippi v. Filippi, 818 A.2d 608 (R.I. 2003) (pour‑over wills transfer assets into inter vivos trusts; such assets are treated in equity as trust property, not probate estate)
Lehigh Cement Co. v. Quinn, 173 A.3d 1272 (R.I. 2017) (standard of appellate review for summary judgment is de novo)
Midland Funding LLC v. Raposo, 222 A.3d 484 (R.I. 2019) (summary judgment affirmed where no genuine issue of material fact exists)
American Express Bank, FSB v. Johnson, 945 A.2d 297 (R.I. 2008) (reciting burdens for opposing a summary judgment motion)
Goddard v. APG Security‑RI, LLC, 134 A.3d 173 (R.I. 2016) (treating a premature notice of appeal as timely under specified circumstances)