Platt v. Griffith
| Decision Date | 27 May 2021 |
| Docket Number | Record No. 190817 |
| Parties | Mary Carroll Griffith PLATT, et al., Appellants, v. Mary Catherine Miles GRIFFITH, et al., Appellees. |
| Court | Virginia Supreme Court |
Upon consideration of the record, briefs, and argument of counsel, the Court is of opinion that there is no error in the judgment of the circuit court.
Dr. Lloyd Tayloe Griffith ("Dr. Griffith") died in December 2016. Dr. Griffith was survived by his three adult children: two daughters, Mary Carroll Griffith Platt and Lindsay Carr Griffith Farino (collectively, the "appellants"), and a son, Charles Tayloe Griffith ("Charles"). Dr. Griffith was also survived by his second wife, Mary Catherine Miles Griffith ("Mary Cate"). At the time of his death, Dr. Griffith had executed several documents pertaining to the distribution of his estate.
Under Dr. Griffith's 2008 will, the residue from the estate, which included a 704-acre farm ("Albany Farm"), was to be placed in a trust for Mary Cate's benefit. If Mary Cate predeceased Dr. Griffith, Albany Farm would go to Charles, apart from two 10-acre parcels of land to be given the appellants.
Dr. Griffith executed a new will in October 2010, revoking and replacing all prior wills. The 2010 will devised to each of the appellants a 20-acre parcel of Albany Farm, with the remainder going to Mary Cate and Charles. Further, the 2010 will left Mary Cate a 55-acre estate in Westmoreland County and all other real estate owned solely by Dr. Griffith, in addition to all personal property that Dr. Griffith owned or shared with Mary Cate.
In 2014, Dr. Griffith executed a deed of gift of personal property (the "chattel deed"), immediately transferring to Mary Cate all personal property located in the Albany Farm residence and in their shared residence in the City of Richmond. Six months prior to his death in 2016, Dr. Griffith executed a deed of gift (the "deed of gift"), conveying a life estate in the Albany Farm residence to Mary Cate. The deed of gift gave Charles the entirety of Albany Farm, subject to Mary Cate's life estate in the residence. Notably, the deed of gift did not reserve the two 20-acre parcels devised to the appellants in the 2010 will.
Charles, acting as the personal representative of Dr. Griffith's estate, filed a suit for aid and guidance, requesting to probate the 2010 will after initially probating the 2008 will. The appellants challenged the validity of the 2010 will. The circuit court found by clear and convincing evidence that Dr. Griffith intended the 2010 will to constitute his operative will and ordered that the 2010 will be entered into probate. The appellants did not appeal the circuit court's order.
In August 2018, the appellants filed a complaint listing Mary Cate and Charles, in his individual capacity, as defendants. The complaint alleged that Mary Cate and Charles committed a breach of fiduciary duty, waste of the estate, constructive fraud, conversion, conspiracy to commit conversion, business conspiracy, and undue influence. More specifically, the appellants alleged that Mary Cate unduly influenced Dr. Griffith to sign the chattel deed. Further, the appellants alleged that in 2016, Charles and Mary Cate conspired to convert $13,000,000 of Dr. Griffith's assets using their confidential relationship to exert undue influence over Dr. Griffith.
The appellants demanded a judgment of over $13,000,000 and an order requiring an accounting of Dr. Griffith's real and personal property owned as of the execution of the 2010 will, with that property being placed in a constructive trust. They demanded the restoration of the value of Dr. Griffith's property to what it was before the alleged violations by Mary Cate and Charles. The appellants further demanded that the circuit court declare the chattel deed and the deed of gift void ab initio. The appellants requested punitive damages and attorneys’ fees.
Mary Cate and Charles individually moved to dismiss the appellants’ complaint based on lack of standing. The circuit court dismissed the complaint with prejudice. The circuit court noted that the transfers at issue occurred during Dr. Griffith's lifetime. As such, the circuit court concluded that only Dr. Griffith's personal representative could bring the claims. The circuit court specifically held that the appellants did not have "any right, title or interest" to the property at issue. The circuit court explained that the 2010 will extinguished any expectation held by the appellants as to personal property. Similarly, the circuit court explained that the deed of gift extinguished the prior testamentary gifts of the two 20-acre parcels on Albany Farm.
The appellants opposed the entry of the proposed final order and sought leave to amend their complaint. The appellants alleged that once Dr. Griffith died, the appellants’ interests "vested," giving them standing. After hearing argument, the circuit court entered an order dismissing the appellants’ claims with prejudice.
On appeal, the appellants maintain that they have standing to pursue the rescission of the inter vivos deeds because they are "vested beneficiaries" of two 20-acre parcels of Albany Farm.
We review de novo the question of whether the appellants’ factual allegations were sufficient to establish standing, as this issue presents a question of law. See Deerfield v. City of Hampton , 283 Va. 759, 764, 724 S.E.2d 724 (2012) ; Virginia Marine Res. Comm'n v. Clark , 281 Va. 679, 686-87, 709 S.E.2d 150 (2011), overruled in part on other grounds by Woolford v. Virginia Dep't of Taxation , 294 Va. 377, 390, 806 S.E.2d 398 (2017) ; Philip Morris USA Inc. v. Chesapeake Bay Found., Inc. ,...
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