Lackman v. McAnulty, 151 A.3d 1271

Decedent Hugh I. Hunt executed a revocable inter vivos trust (1999) and later quitclaimed real property (6 North Street, Goshen) to himself "as trustee" in 2004; the quitclaim was recorded but no separate instrument defining trustee powers was recorded.
The trust was not revoked or amended to exclude the property after the quitclaim; decedent remained sole trustee and beneficiaries were his children.
In 2011 the decedent executed a will that specifically devised the same property to the plaintiffs (two of his children) and another child; the decedent died in 2013.
Executors/refusing distribution: the executrix (a trustee-beneficiary) declined to deliver the property under the will, asserting the property remained trust corpus and thus outside probate. Plaintiffs sued for declaratory relief/quiet title.
Trial court granted summary judgment for defendants (trust beneficiaries), holding § 47-20 did not void the quitclaim or permit the property to pass under the will; plaintiffs appealed to the Connecticut Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Conn. Gen. Stat. § 47-20 nullify a quitclaim to the grantor "as trustee" when no separate trustee-power instrument is recorded, so the property remains the grantor's and can be devised by will?	§ 47-20’s phrase "otherwise dispose of" includes wills; failure to record a separate instrument makes the word "trustee" a nullity (Benassi), so property stayed with decedent and passed by will.	§ 47-20 protects third-party transferees of a trustee’s subsequent conveyance; a will is not a present transfer to a third party and the statute does not apply here.	Held for defendants: § 47-20 does not apply because it addresses protection of third-party grantees in a second conveyance; the quitclaim validly placed the property in the trust and the devise adeemed.

Benassi v. Harris, 147 Conn. 451 (1960) (court applied § 47-20 to invalidate a recorded designation "as trustee" where a developer’s subsequent transfer to third parties required protection for the original grantor)
Socha v. Bordeau, 277 Conn. 579 (2006) (recognizes that conveying property to oneself "as trustee" places legal title in trustee and subject to trust corpus)
Hansen v. Norton, 172 Conn. 292 (1976) (same principle: a grantor who conveys to himself as trustee no longer holds the individual estate)
Gonzalez v. O & G Industries, Inc., 322 Conn. 291 (2016) (describes plenary review and statutory-construction methodology relied on in analyzing § 47-20)