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As much as law is about complex theories and inferential reasoning, it is also very much about procedures and deadlines. As we have discussed numerous times before, entire cases can literally be transformed by a simple procedural mistake; this is true even when there might have been valid arguments on either side. This is just one of the many reasons as to why procuring competent counsel during a legal case be so critical: a capable lawyer will know all the procedural rules which apply in a given situation, and can help avoid any pitfalls in this area.
The case of Ibru v. Ibru (2018) is a fascinating case. There is lots to unpack in this complex estate case, as the litigation involved multiple issues. But, in this post, we will summarize one of the primary issues in this case, an issue which involved subject matter jurisdiction for equity courts here in Maryland. Let’s explore this case in some detail.
Facts of the Case
The main subject of this case, Chief Ibru, was a wealthy immigrant originally from Nigeria. Mr. Ibru’s estate was valued at nearly $2 billion at the time of his passing, although only a fraction of that wealth was located within the United States. Prior to Mr. Ibru’s death in September of 2018, Mr. Ibru appointed his daughter, Janet, as attorney-in-fact in a power of attorney arrangement. Later, he granted his general powers of attorney. The purpose of this POA arrangement was to ensure that Janet could manage his finances for his healthcare. The POA gave Janet access to certain financial accounts which Mr. Ibru had established in the U.S.
Prior to Mr. Ibru’s death, one of Mr. Ibru’s sons, Peter, attempted to enjoin Janet from exercising her rights under the POA arrangement. Peter claimed that Janet had exerted undue influence in obtaining the POA arrangement and that, consequently, the rights acquired via POA were void. Peter brought his legal actions to an equity court (i.e. circuit court) in Maryland. Janet argued that the case should be dismissed based on lack of subject matter jurisdiction because the equity court lacked the ability to hear estate cases. At the trial court level, Janet prevailed: the court determined that the case was indeed an estate case which should’ve been filed in the Orphan’s Court, that Peter lacked standing to bring the case, and that Peter should pay Janet’s attorney fees. Peter then filed an appeal.
Ruling & Discussion
Again, there were multiple complex issues occurring in this case, but the one we want to focus on is subject matter jurisdiction. On appeal, Peter argued that the trial court’s characterization of the case as an estate case was erroneous, because the case should’ve been properly characterized as a fraud case involving the alleged fraudulent acquisition of rights via POA. And, because equity courts have jurisdiction over fraud cases, the circuit court did in fact have subject matter jurisdiction to hear the case.
The appellate division concurred with Peter’s argument with respect to subject matter jurisdiction. Even though this case does intersect with estate issues, Peter’s suit was fundamentally concerned with the rights acquired via POA. And, because Peter alleged that these rights were acquired in a fraudulent manner, the circuit court did in fact have subject matter jurisdiction. Consequently, the trial court’s determinations were overturned, and the attorney fees awarded to Janet were cancelled.
Contact the Murphy Law Firm for More Information
If readers would like additional information on POAs, durable POAs, healthcare directives, wills, or any other estate planning topic, contact one of the estate planning attorneys at the Murphy Law Firm today by calling 240-219-5243.
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