The Indiana Court of Appeals has held that two siblings who have accused their mother of fraud with regard to a family trust account did not present any material issue of fact to support their argument.

In Julie R. Waterfield Irrevocable Trust Agreement Dated October 21, 1997; Richard R. Waterfield and J. Randall Waterfield v. The Trust Company of Oxford and Julie R. Waterfield, No. 49A04-1103-TR-95, Julie Waterfield is the sole beneficiary of a trust created by her parents. After Julie Waterfield’s death, her sons, Richard and Randall Waterfield, would receive annual distributions from a “pour-over” trust in the amount of $25,000 each.

Julie Waterfield’s mother, Ruth Rhinehart, made a $1.5 million pledge from the trust, and Rhinehart’s attorney and financial adviser told her that she would need to reform the trust in order to accomplish her objectives. Julie Waterfield obtained signatures from Richard and Randall, as required to reform the trust.

The two men claimed that Julie Waterfield fraudulently obtained their signatures, but the COA held that their claims for fraud and constructive fraud are not supported by any evidence of actual injury. The appellate court also held that the men had been unable to prove that their distributions from a pour-over trust would in any way be affected by the reformation of Julie Waterfield’s trust. The COA affirmed the trial court’s entry of summary judgment in favor of Julie Waterfield and The Trust Company of Oxford.