Joanne Miller v. Henry Saunders
80 A.3d 44
R.I.2013Background
- Joanne Miller and Dean Miller divorced in 2006; their property-settlement agreement (not merged into the decree) required Dean to maintain life insurance "for the benefit of the minor children."
- In 2007 Dean designated the four children as life-insurance beneficiaries and wrote in a service request: "Beneficial interests to be paid to and managed by Kristin Saunders as custodial trustee for the benefit of my minor children."
- Dean died in 2012; policy proceeds were paid to Kristin (Mrs. Saunders) as custodial trustee.
- Joanne sued seeking a declaration that the children (not Mrs. Saunders) were the beneficiaries and sought distribution/accounting of proceeds; a TRO was entered and later vacated.
- Defendants moved for summary judgment; the Superior Court held Dean had validly created a custodial trust under the Rhode Island Uniform Custodial Trust Act (RIUCTA), and that the trust did not violate the property-settlement agreement. The Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dean had the legal right under the property-settlement agreement to create a custodial trust | Miller: Agreement required insurance be for children’s benefit and stripped Dean of any right to designate recipients or divert proceeds to a trustee | Saunders: Dean named the children as beneficiaries and complied with the agreement by preserving benefits for them even though he designated a trustee | Court: Agreement was unambiguous; naming children as beneficiaries satisfied the obligation and did not forbid designating a trustee |
| Whether Dean’s handwritten designation satisfied RIUCTA’s written-declaration requirement (must be in substance: "as custodial trustee ... under the Rhode Island Uniform Custodial Trust Act") | Miller: The service form did not cite RIUCTA or use the exact statutory wording, so it failed to create a statutory custodial trust | Saunders: The handwritten language identified a custodial trustee and beneficiaries and thus met the statute "in substance" | Court: "In substance" requires the essential formulation, not verbatim text; the handwritten instruction satisfied RIUCTA and created a valid custodial trust |
Key Cases Cited
- Carreiro v. Tobin, 66 A.3d 820 (R.I. 2013) (summary-judgment standard on appeal reviewed de novo)
- Great American E & S Insurance Co. v. End Zone Pub & Grill of Narragansett, 45 A.3d 571 (R.I. 2012) (summary-judgment appellate standard)
- Furtado v. Goncalves, 63 A.3d 533 (R.I. 2013) (construction of property-settlement agreements not merged into judgment)
- DiPaola v. DiPaola, 16 A.3d 571 (R.I. 2011) (contract ambiguity and plain-meaning rule)
- Morel v. Napolitano, 64 A.3d 1176 (R.I. 2013) (statutory-construction principles and giving clear language its plain meaning)