St. Malachy Roman Catholic Congregation of Geneseo, Illinois Steve Bristol Conni Bristol and Kewanee Area United Way v. Donna K. Ingram, as of the Estate of James Ingram, and Robert W. Baird & Co., Inc.
2013 Iowa Sup. LEXIS 133
| Iowa | 2013Background
- Estate of Alvin Engels: Revocable Trust and Charitable Foundation created; Ingram involved as adviser, executor, and cotrustee; Tarbox drafted 2003 Will and Charitable Trust terms; 2004 quitclaim deed attempted transfer of Engels’s home to the Charitable Trust but title remained in the Revocable Trust; Engels’s death in 2006 left Bristol as specific heir to the Geneseo home while charitable gifts were discretionary under the Trust; district court granted summary judgment to Ingram and Baird, appellate court reversed in part and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Ingram owe a duty to the beneficiaries? | Bristol argues Ingram’s agency extended to estate planning duties. | Ingram and Baird contend no duty to beneficiaries existed. | Yes, a duty could arise; genuine issues of material fact remain. |
| Does Schreiner extend to nonattorney agents? | Schreiner duty should apply to Ingram as an agent in estate planning. | Limitations apply; only attorneys owe such duties. | Schreiner extends to nonattorneys acting within agency scope. |
| Is economic loss doctrine applicable to these claims? | Duty from agency allows recovery despite economic loss. | Economic loss doctrine bars such damages absent exception. | Economic loss rule does not bar because duty arises from principal–agent relationship. |
| Are damages too speculative for St. Malachy’s and United Way? | Distributions under the Trust would have favored them; damages are provable. | Damages too speculative; recovery denied for those claims. |
Key Cases Cited
- Schreiner v. Scoville, 410 N.W.2d 679 (Iowa 1987) (duty to identifiable beneficiaries under testamentary instruments")
- Holsapple v. McGrath, 521 N.W.2d 711 (Iowa 1994) (extension to identifiable beneficiaries of nontestamentary instruments)
- Pitts v. Farmers & Merchants Savings Bank, 818 N.W.2d 95 (Iowa 2012) (duty under agency/principal relationships; beneficiaries’ relief)