What Not to Wear: Court Edition

by: , December 16, 2013

Effective November 18, 2013, there are some important procedural changes affecting estate, trust, and capacity matters in Toronto. For some time now, the Toronto court has maintained a separate “Estates List” to hear all matters relating to the administration of trusts and estates and substitute decision making.  As an estates litigator, I have been an…read more

When A Custody Battle Turns into Competing Guardianship Applications

by: , December 6, 2013

In a recent Ontario case, divorced parents each sought sole guardianship of their mentally incapable adult daughter. The parents, who divorced in the 1980s, were unable to work together as joint guardians of their 42 years old mentally incapable daughter (“Isabella”). While both parents, who are now in their 70s, agreed that it would be ideal…read more

When Will the Court Appoint an ETDL?

by: , November 12, 2013

The recent endorsement of Justice Greer in McColl v. McColl illustrates the broad authority of the Court to appoint an Estate Trustee During Litigation (ETDL), and where warranted, to dispense with the requirement that the ETDL post a bond. The deceased was survived by his second wife, ex-wife and son from his first marriage.  At the time…read more

Lawyer’s Questionnaire Admitted to Probate as a Will

by: , November 4, 2013

Courts are sometimes asked to determine if a “testamentary-like” document is a will.  In British Columbia, an executor brought an action to prove in solemn form that a questionnaire that the testator (“Ms. Garnett”) filled out and signed before two witnesses shortly before her death was a will that could be submitted for probate. Ms. Garnett was…read more

A Resulting Trust May Arise Before Death

by: , October 25, 2013

In estate disputes, it is common for parties to try to claw back into the estate bank accounts that were held jointly with the testator before death. The law provides a mechanism to do this – a resulting trust. Briefly, a resulting trust works as follows: any time property is transferred to someone else for…read more

When Will A Court Order a Mental Examination?

by: , October 17, 2013

In what circumstances will a court order a plaintiff to undergo a mental examination to determine whether she is a party under a legal disability who has to be represented by a litigation guardian? This was one of the issues for the court to determine in the recent Ontario case of 626381 Ontario Limited et al….read more

When Co-Estate Trustees Cannot Agree To Sell The House

by: , October 8, 2013

While administering an estate, one of the most difficult challenges an estate trustee can face is the situation where a beneficiary continues to reside in a property that is an estate asset when the estate trustee wishes to list the property for sale.  When there is disagreement on this issue amongst co-estate trustees, an estate…read more

If There is a Valid POA, the Court Cannot Order a Guardianship

by: , September 30, 2013

The recent decision in Lehtonen v. Neill serves as a useful reminder of the sometimes overlooked subsection 22(3) of the Substitute Decisions Act.   This provision prohibits the court from appointing a guardian where the court is satisfied that decision making for the incapable person can be met by a less intrusive means.  It says: The Court shall not…read more

Post Security or Go Home

by: , September 20, 2013

You don’t often hear about a motion for security for costs in estate litigation (if nothing else the parties are usually very much present in the jurisdiction and have some financial worth).  However, estate litigants have been ordered to post security for costs just as in any other civil litigation.  Equally, estate litigants have successfully…read more

The Reward For Civility: No Costs Against You

by: , September 12, 2013

Justice DiTomaso recently released an interesting costs decision following his reasons in the case of Stevens v. Fisher Estate (blogged on earlier this year by Jasmine Sweatman on All About Estates). Due to the good conduct of the parties, the Court ordered each side to bear its own costs. By way of quick recap of…read more