Yenchi, E. v. Ameriprise Financial, Aplts., Yenchi, E. v. Ameriprise Financial, Aplts.

Plaintiffs Eugene and Ruth Yenchi paid $350 for a "Financial Management Proposal" prepared by Bryan Holland, labeled "Confidential" and identifying Holland as an "American Express financial advisor." The proposal led to consolidation of the Yenchis' life insurance policies in 1996.
The Yenchis testified they trusted Holland, relied on his expertise, spoke only with him about their finances, and often signed documents he prepared without reviewing them.
The Yenchis later sued Ameriprise/Riversource and Holland alleging breach of fiduciary duty (among other claims) related to the insurance consolidation.
The trial court granted summary judgment for the defendants on the fiduciary-duty claim; the Superior Court reversed.
Justice Todd (joined by Justice Wecht) dissented from the Supreme Court majority, arguing that factual indicators of a confidential/fiduciary relationship were sufficient to defeat summary judgment and that the Superior Court should be affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a confidential/fiduciary relationship existed between the Yenchis and Holland/Appellants such that summary judgment for defendants was improper	Yenchi: payment for a confidential, fee-based financial proposal, labeling of Holland as "advisor," plaintiffs' trust and reliance, and signing documents without review created factual disputes about a fiduciary relationship	Defendants: relationship was ordinary agent-client or salesperson; no surrender of substantial control, Holland was a "captive" advisor, no explicit promise of loyalty, so no fiduciary duty as a matter of law	Majority: affirmed summary judgment for defendants (no fiduciary relationship as a matter of law). Dissent (Todd): would reverse — factual issues about trust/reliance preclude summary judgment and support a jury determination of a confidential relationship

Basile v. H & R Block, Inc., 52 A.3d 1202 (Pa. 2012) (confidential-relationship inquiry is intensely fact-specific; essence is trust and reliance and opportunity to abuse that trust)
Estate of Scott, 316 A.2d 883 (Pa. 1974) (discusses confidential relationship concept and control-surrender language in business contexts)
Frowen v. Blank, 425 A.2d 412 (Pa. 1981) (general test for confidential relationship: parties do not deal on equal terms; one side has overmastering influence or the other places trust/dependence)
Brooks v. Conston, 51 A.2d 684 (Pa. 1947) (confidential relationship exists where one occupies an advisor role that reasonably inspires confidence to act in the other's interest)