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

Court Need Not Always Order a Fiduciary to Account

by: , September 4, 2013

In an earlier blog by fellow blogger Jasmine Sweatman, she commented on the emerging principle of proportionality in our judicial system and how it might impact on a fiduciary’s duty to pass accounts.  She queried: Where does proportionality “fit” with the right of a beneficiary of an estate or trust  to review and make inquiries of the…read more

When Is It Too Late To File A Notice Of Objection To The Appointment Of An Estate Trustee?

by: , August 26, 2013

In a recent case, the court had to determine if a notice of objection to the issuance of an appointment of an estate trustee could be filed after summary judgment had been granted, striking another objector’s objections as invalid and a certificate of appointment had been issued to the estate trustees. By way of background, the…read more

Enzo the Mixer

by: , August 8, 2013

May an attorney for property mix his own funds with that of the incapable person? The short answer is: never. But the consequences for a well-meaning but ill-advised client might not be as dire as we litigators sometimes would expect. In the recent case of Villa v. Villa 2013 ONSC 2202, two brothers, Renzo and Enzo Villa, clashed…read more

Keep the Trains Running: The Importance of a Status Hearing

by: , July 30, 2013

In a recent decision by the Ontario Court of Appeal, the court turned its attention to a frequently encountered issue in civil litigation: under what circumstances should an action be dismissed  for delay by the court following a status hearing?  The appellant (plaintiff) appealed a lower court order dismissing the action for delay after a status hearing….read more

The Paul Penna Estate: Summary Judgment Appealed

by: , December 16, 2008

Introduction In an earlier edition of Deadbeat,[1] I wrote a case comment on the decision of Greer J. granting partial summary judgment in the Estate of Paul Penna.[2]  The decision was appealed.  As recently reported in the Ontario Reports, the Court of Appeal (“C.A.”) dismissed the appeal.[3]  What follow is a consideration of the C.A.’s…read more

A Child’s Interest in the Family Cottage

by: , January 27, 2007

Recently, a client came to me regarding the purchase of a family cottage.  The client was obviously excited about his new purchase, and wanted advice as to whether he should include his minor children on title.  As his children would ultimately inherit the cottage, he thought it would be a good idea to include them…read more