Maratty v. Pruitt
334 S.W.3d 107
| Ky. Ct. App. | 2011Background
- Decedent Irvin W. Pruitt died intestate in Jefferson County (2000).
- Vera Mae Pruitt was appointed administratrix of the estate in district court.
- Vera sold the liquor store and associated real property; an audit showed $29,293.65 profit to the estate.
- In 2006 the district court approved a final settlement, granting Maratty about $7,323.47, and improper charges against Maratty’s share were addressed.
- Vera appealed the district court’s settlement to the circuit court; in 2008 Maratty, Thomas, and Meinhart filed a circuit action alleging fiduciary breach; the circuit court granted summary judgment on res judicata grounds.
- The issue is whether the circuit action is barred by the district court’s final settlement and whether district court had jurisdiction over fiduciary accounting issues in that settlement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars the circuit action | Maratty argues district court lacked jurisdiction to adjudicate fiduciary breaches | Vera argues prior district court judgment is final and precludes later action | Yes; circuit action barred by res judicata due to identity of parties, causes, and merits disposition |
| Whether district court had jurisdiction over fiduciary settlement matters | Pruitt heirs contend district court could not rule on fiduciary breaches | District court had jurisdiction under KRS chapter 395 to entertain settlements and related accounting | Yes; district court had jurisdiction to entertain and adjudicate proposed settlements and related fiduciary accounting |
| Whether the KRS 62.070 fiduciary bond claim is barred | Claim is on Vera’s fiduciary bond | District court finding of discharge precludes bond action | Yes; claim barred once district court approved settlement and discharged fiduciary and surety |
Key Cases Cited
- Yeoman v. Commonwealth, Health Policy Bd., 983 S.W.2d 459 (Ky. 1998) (discusses res judicata elements and scope)
- Privett v. Clendenin, 52 S.W.3d 530 (Ky. 2001) (limits district court jurisdiction over custodial accounting and fiduciary mismanagement in probate context)
- Priestley v. Priestley, 949 S.W.2d 594 (Ky. 1997) (circuit courts’ jurisdiction over fiduciary settlements; related limitations)
- Lee v. Porter, 598 S.W.2d 465 (Ky. App. 1980) (jurisdictional scope of probate/fiduciary matters)
- Vaughn's Adm'r v. Louisville & N. R. Co., 179 S.W.2d 441 (Ky. 1944) (principle of finality when district court had jurisdiction)