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Keywords

jurisdictionmotionsummary judgmentprobatewillcivil procedure
plaintiffjurisdictionmotiontrustwillcitizenshipcivil proceduremotion to dismiss

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Morris v. Trust Co. of Virginia, Not Reported in F.Supp.3d, 2015 WL 1475487

Facts

Amy Falcon Morris executed two wills, one in 1998 leaving her estate to George Mason University Foundation and another in 2007 leaving it to her family. A Virginia court ruled the 2007 Will invalid due to her lack of capacity, but after her death in Alabama, her son Thomas successfully probated the 2007 Will. This led to a series of legal disputes across Virginia, Alabama, and Maryland, involving multiple court orders and claims against her children for actions taken during her guardianship.

Decedent Amy Falcon Morris executed two wills—one in 1998, and another in 2007. The 1998 Will left almost everything to George Mason University Foundation in Virginia. The 2007 Will left everything to Amy's family.

Issue

The main legal issues include the validity of the 2007 Will, the enforcement of Virginia court judgments against Morris and Duncan, and the jurisdictional conflicts between Virginia and Alabama courts regarding the estate.

The defense of res judicata is universally respected, but actually not very well liked.

Rule

The court applied principles of res judicata, full faith and credit, and the standards for motions to dismiss and summary judgment under Federal Rules of Civil Procedure.

Subject-matter jurisdiction is proper pursuant to 28 U.S.C. § 1332(a). The amount in controversy exceeds $75,000, and there is complete diversity of citizenship between the opposing parties in each case.

Analysis

The court analyzed the conflicting rulings from Virginia and Alabama courts, emphasizing the importance of the Virginia court's prior determination regarding Amy's capacity and the validity of her wills. It considered the implications of the judgments against Mr. Morris and Ms. Duncan, as well as the jurisdictional issues raised by the probate proceedings in Alabama.

When evaluating a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), the court must take the facts alleged in the complaint as true and construe them in the light most favorable to the plaintiff.

Conclusion

The court ultimately upheld the Virginia court's rulings regarding the invalidity of the 2007 Will and the enforceability of the judgments against Morris and Duncan, reinforcing the principle of full faith and credit among states.

The court entered a memorandum opinion and order granting in part and denying in part the Trust Company and the Foundation's motions to dismiss the original complaint.

Who won?

The prevailing party was the George Mason University Foundation, as the court upheld the validity of the 1998 Will and the judgments against Morris and Duncan.

The Foundation seeks to collect two separate Virginia monetary judgments against Mr. Morris and Ms. Duncan arising directly out of Mr. Morris and Ms. Duncan's dealings with Amy's assets during the pendency of the guardianship and conservatorship proceedings in a Virginia Court.

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