Trusts and Estates

Ca. Trs. & Estates Quarterly VOLUME 30, ISSUE 4, 2024

MCLE SELF-STUDY ARTICLE SPEARS V. SPEARS: A SHINY NEW OPTION FOR ENFORCING A CREDITOR’S CLAIM AGAINST A TRUST

Written by John Rueppel, Esq.*

SYNOPSIS

In December 2023, the First District Court of Appeal of California decided Spears v. Spears (2023) 97 Cal.App.5th 1294 ("Spears"), which clarifies (and broadens) the procedural options for a creditor attempting to reach trust assets. Spears makes available the option of directly suing the trust, or filing a petition under Probate Code section 850, when certain prerequisites are met, avoiding the delay and hassle of a formal probate procedure. This article will consider the history of the law and procedure for prosecuting a creditor’s claim against a trust, and the impact of Spears on the current creditor landscape.

I. CREDITOR’S CLAIMS AGAINST ESTATES AND REVOCABLE TRUSTS

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