Rearden v. Riggs National Bank

Hazel M. King created an inter vivos trust, naming Riggs National Bank of Washington, D.C. (Riggs) and Sanford Goldstein (defendants) as cotrustees. The trust provided that King would receive lifetime distributions from the trust, and that when King died, the trust remainder would go to personal representatives of King’s estate to be distributed pursuant to King’s will. The trustees would be required to provide to the personal representatives of King’s estate a final accounting. The personal representatives were Riggs, Goldstein, and Lillian Malins, a former long-standing secretary to Goldstein’s father. King died in 1991, and the bulk of King’s estate was the remainder of the trust estate, worth approximately $1.6 million. King’s sister, niece, and nephew (collectively, King’s family) (plaintiffs), who were the residuary legatees under King’s will, sought a final accounting of the trust in probate court. Riggs and Goldstein refused to provide the accounting, so King’s family sought relief in two courts. First, King’s family filed objections in probate court when Riggs, Goldstein, and Malins attempted to close the estate. Second, King’s family filed suit against Riggs and Goldstein in civil court, seeking a final accounting of the trust and challenging the amount of compensation that the trustees had paid themselves from the trust. The probate court held that Riggs, Goldstein, and Malins were required to provide King’s family with a final accounting but held its order in abeyance pending the civil action. In the civil trial court, Riggs and Goldstein filed a motion for summary judgment, which the trial court granted, holding that King’s family did not have any right to bring suit to challenge the trust administration, because they were not beneficiaries of the trust. King’s family appealed.