Background
Ronald Jennings and Debra Miner are the children of Leroy and Gwendolyn Jennings, who established parallel revocable trusts. Their 2020 amendments left the trusts’ real estate and remaining assets to Miner while stating that Ronald was intentionally left nothing because of prior advances and because he would receive at least one equity account outside the trusts upon both settlors’ deaths.
Ronald alleged that his parents intended him to receive additional equity accounts and that, in December 2023, Miner presented Gwendolyn with paperwork supposedly confirming that one account would pass to Ronald. According to the petition, the paperwork instead kept or placed the account—valued between $100,000 and $500,000—in the trusts or made it payable to Miner. After Gwendolyn died, Ronald sued to modify or reform the trusts, alleged breach of trust and fiduciary duty, and alternatively claimed that Miner tortiously interfered with his expected inheritance. The circuit court dismissed the entire petition for failure to state a claim.
The Court’s Holding
The Court of Appeals affirmed dismissal of the trust-related claims. Missouri’s Uniform Trust Code permits only a trustee or beneficiary to commence a proceeding seeking modification or reformation under the provisions Ronald invoked. Because Ronald was neither—and the trusts expressly stated that he was not a beneficiary—he could not create standing by arguing that the requested proceeding might make him a beneficiary. Miner consequently owed him no duty as trustee. Ronald also abandoned on appeal his fiduciary-duty claim and his claims involving farm rent, cash allegedly intended for a grandson, residual trust assets, and other declaratory relief.
The court reversed dismissal of the alternatively pleaded tortious-interference claim, but only as to the disputed equity account valued between $100,000 and $500,000. Taking the pleaded facts as true, Ronald sufficiently alleged an inheritance expectancy, independently tortious conduct through Miner’s alleged subterfuge, surreptitious conduct, and self-dealing, intentional interference, causation, and damages. The court expressed no view on whether Ronald could prove those allegations and noted that Miner might seek a more definite statement identifying the underlying tort.
Key Takeaways
- Under Missouri’s Uniform Trust Code, only a trustee or beneficiary may initiate the statutory trust-modification or reformation proceedings at issue.
- A person expressly excluded as a trust beneficiary cannot bootstrap standing from the possibility that successful reformation would make that person a beneficiary.
- Detailed allegations that someone used independently tortious conduct to redirect a specific nonprobate asset can state a claim for tortious interference with inheritance at the pleading stage.
Why It Matters
The decision sharply distinguishes statutory challenges to trust terms from tort claims based on interference with an expected transfer. A disinherited person may lack standing to rewrite a trust yet still have a potential remedy against an individual who allegedly used tortious means to divert a specific asset that otherwise would have passed outside the trust.
The ruling is narrow: only the claim concerning the identified equity account returns to the circuit court. All other portions of the dismissal remain intact.