Is a Formal Capacity Assessment Required Evidence?

by: , November 19, 2024

When the court appoints a guardian of property or guardian of the person the court must make a finding of incapacity (ss. 25(1) and 55(1) of the Substitute Decisions Act, SO 1992, c 30 (the “SDA”).  Often parties will obtain or seek to obtain a formal capacity assessment to provide to the court as evidence…read more

Mandatory Mediation: Where, What, Why

by: , September 10, 2024

For more than two decades, mediation has been mandatory in certain jurisdictions in Ontario for most matters involving estates, trusts, and substitute decisions. Toronto, Ottawa, and the County of Essex are subject to mandatory mediation pursuant to and governed by rule 75.1 of the Rules of Civil Procedure, RRO 1990, O. Reg. 194. The types…read more

When You Can’t Afford a Funeral

by: , July 29, 2024

A CBC news article published last week highlighted a mother’s grief after the death of her daughter because the family could not afford a funeral.  Tragically, the body of the deceased daughter was held in a hospital freezer as the morgue was at capacity.  While the CBC article mentioned financial assistance available in Newfoundland and…read more

Capacity to Grant and Revoke Powers of Attorney

by: , May 7, 2024

The validity of powers of attorney can be challenged on the basis that the grantor was incapable when she signed the power of attorney. The requisite capacity to grant a power of attorney for property is set out in s. 8(1) of the Substitute Decisions Act, 1992, SO 1992, c. 30 (the “SDA”) which provides…read more

The Scope of Cross-Examination on an Interlocutory Motion

by: , March 4, 2024

A deponent or affiant may be cross-examined on their affidavit sworn in support of or in response to a motion.  If a question on cross-examination is not answered, then it will be deemed a refusal.  The examining party may bring a refusals motion to compel answers to the refused questions should they be maintained.  Sometimes…read more

Principles of Will Interpretation

by: , December 22, 2023

In the recent case of Kurt v. Kurt and Sullivan, 2023 ONSC 6599 (CanLII), (“Kurt”), the Court was asked to consider the interpretation of a will. The parties agreed on most of the salient facts, but disagreed with respect to the interpretation of one clause of the deceased’s secondary will. The Court reviewed the legal…read more

Court-ordered Wills and s. 21.1(1) of the SLRA

by: , October 23, 2023

January 2022 brought significant changes to a governing statute in estates law: the Succession Law Reform Act[1]. One such change provides the Court with authority to declare a will valid and fully effective despite its non compliance with legislative requirements for formal execution.[2]  The legislative requirements provide that a will is not valid unless: (a) it…read more

Punitive Damages Against Estate Trustees Can Happen

by: , August 22, 2023

The fiduciary relationship should not be entered into lightly. Examples of fiduciaries in estates and trusts law are estate trustees, attorneys, and guardians. The fiduciary owes legal duties to the beneficiary, for example an estate trustee must account for her management of estate assets. Failure to do so can lead to trouble for the estate…read more

Who Gets Appointed as Estate Trustee During Litigation

by: , July 3, 2023

An Estate Trustee During Litigation (“ETDL”) is an individual appointed by the Court to administer an estate (other than distributing the residue of the estate) while the estate is in litigation. The Court has authority to appoint an ETDL under s. 28 of the Estates Act or rule 75.06(3)(f) of the Rules of Civil Procedure….read more

Blended Costs Awards in Estate Litigation

by: , April 3, 2023

Costs follow the event. This can be translated as the “loser pays” principle which has applied in estate litigation for many years now (since at least the seminal decision in Salter v. Salter Estate, 2009 CanLII 28403 (ON SC), decided by Justice D.M. Brown, as he then was). But in estate litigation there is often…read more