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In re Leona Carlisle Trust

498 N.W.2d 260 (1993)

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In re Leona Carlisle Trust

Minnesota Court of Appeals
498 N.W.2d 260 (1993)

Facts

James Carlisle (plaintiff) had severe cerebral palsy. His mother, Leona Carlisle, cared for James and assisted James with his daily living activities until she was no longer able to do so in 1979. James then applied for and was granted Medicaid, known as medical assistance in Minnesota, from Dakota County Human Services (the county). To be eligible for medical assistance, an applicant could not have more than $3,000 in assets. In 1985 Leona placed $125,000 in trust for James’s benefit. Under the trust, the trustee had sole discretion to distribute money to James for James’s entertainment, education, travel, convenience, and reasonable luxuries. The trustee had no obligation to make any distributions to James. The trust further provided that the trustee could not make distributions for food, shelter, clothing, medical care, or any other of James’s basic necessities, and that the distributions could only supplement but not supplant public assistance. In 1992 the county determined the trust was an available asset and James’s benefits would be terminated. James filed a petition seeking an order that the trust was not an available asset. The trial court held that the trust was an available asset, and James appealed.

Rule of Law

Issue

Holding and Reasoning (Anderson, C.J.)

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