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Keywords

trialtrustunjust enrichmentconstructive trust

trialtrustwillbad faithrespondentconstructive trust

Related Cases

In re Estate of Couture, 166 N.H. 101, 89 A.3d 541

Facts

The decedent, Lucien Couture, designated his wife, Hellen Couture, and their daughter as beneficiaries of his life insurance policy. However, the decedent's son, Thomas Couture, filed a petition for a constructive trust over the proceeds, claiming that Hellen had fraudulently induced Lucien to marry her. The trial court found that Hellen had a concurrent relationship with another man and had misrepresented her relationship to Lucien, leading him to believe he was the father of her child. After Lucien's suicide, the court imposed a constructive trust on Hellen's share of the insurance proceeds, which had been placed in escrow.

The parties either do not dispute, or the record establishes, the following facts. The petition for a constructive trust is grounded upon the claim that the respondent, the decedent's wife, through fraud, deceit, and misrepresentation, induced the decedent to marry her after she gave birth to a daughter whom she claimed was his.

Issue

Did the trial court err in imposing a constructive trust on the life insurance proceeds paid to the decedent's wife?

The respondent first argues that the petitioner lacks “standing” in the instant dispute, even though he is one of the decedent's heirs, and even though she concedes in her brief that “[i]n the event that the constructive trust is upheld,” the life insurance proceeds will be “award[ed] … to the Estate.”

Rule

A constructive trust may be imposed to prevent unjust enrichment when one party has wrongfully obtained property through fraud or deceit, and the party seeking the trust has a legal or equitable interest in the property.

A constructive trust will be imposed whenever necessary to satisfy the demand of justice.

Analysis

The court applied the rule by examining the evidence presented at trial, which showed that Hellen Couture had deceived Lucien into marrying her and designating her as a beneficiary. The court found that the relationship between Hellen and Lucien was based on misrepresentation, and that allowing Hellen to retain the proceeds would result in her unjust enrichment. The court concluded that the evidence supported the imposition of a constructive trust to rectify the situation.

The trial court found, and the record supports its finding, that the respondent fraudulently induced the decedent because she married him without telling him of her concurrent relationship with Tamara.

Conclusion

The Supreme Court affirmed the trial court's decision to impose a constructive trust on Hellen Couture's share of the life insurance proceeds, ruling that the evidence supported the findings of fraud and unjust enrichment.

Accordingly, the trial court found, and the record supports its finding, that the decedent and the respondent had a confidential relationship (a marriage) into which the decedent entered because of the respondent's “bad faith, deceit and misrepresentations.”

Who won?

Thomas Couture prevailed in the case because the court found that he had standing to seek a constructive trust and that the evidence supported his claims against Hellen Couture.

The petitioner has standing to seek a constructive trust because, as one of the decedent's heirs, he has a direct legal or equitable interest in the decedent's estate.

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