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Estate of Gist

Iowa Supreme Court
763 N.W.2d 561 (2009)


Alice and Glenn Pirie executed a will which left their assets in trust for their daughter, Elenore Gist, during her lifetime. The trust required the trustee to pay to Elenore trust income and assets “as may be necessary to provide her with a reasonable standard of living, considering any other means of support or resources which she may have.” The trust also contained a spendthrift provision, which provided that the trust income and assets could not be used to pay the debts of creditors except as necessary to carry out the purposes of the trust. At the time of Elenore’s death she had been receiving Title XIX benefits for many years. The Iowa Department of Human Services (the state) (plaintiff) filed a claim in probate court for the amount of medical assistance it had paid to Elenore during her lifetime. The trustees of Elenore’s trust (defendants) denied the claim. The district court held that the trust was a discretionary support trust intended for Elenore’s benefit, and must be used to repay her medical assistance debt. The trustees appealed, arguing that the trust was not subject to Elenore’s medical assistance debt, and that if it was, the trust’s spendthrift provision defeated the state’s claim for reimbursement.

Rule of Law


Holding and Reasoning (Wiggins, J.)

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