Subject Matter Jurisdiction in a MN Probate
In a probate proceeding, the personal representative of the estate files an application with the probate court in the county where the decedent lived at the time of his or her death. This process triggers entry into probate court. All counties in Minnesota have probate courts to hear matters relating to the administration of an estate. However, there is some confusion about the scope of a probate courts authority to hear other matters subject-matter jurisdiction in legal parlance. This article clarifies probate court jurisdiction in Minnesota.
Historically, Minnesota limited the probate courts jurisdiction over other matters not specifically related to probate. Previously, the Minnesota Constitution gave probate court exclusive jurisdiction over the estates of deceased persons and those under guardianship. In re Petersons Estate, 202 Minn. 21, 39 (1938). Put another way, probate court had jurisdiction only over matters directly connected to the estate in question. However, the Minnesota Supreme Court later held the rule announced in Estate of Peterson no longer applied. Instead, the creation of the Minnesota Court of Appeals essentially consolidated the probate court into Minnesota district courts. In re Estate of Janecek, 610 N.W. 2d 638, 640. (Minn. 2000).
Estate of Janecek expanded the scope of matters over which the probate court may hear. In re RIJ Revocable Trust 2014 WL 685698 (Minn. Ct. App. Feb. 24, 2014), is an example. The decedent in RIJ Revocable Trust established a remainder trust for spousal maintenance. Id. at *1. Prior to his death, the father revoked the trust, disinherited two of his children, and devised his entire estate to his daughter. Id. The decedents two other children filed complaints in probate court alleging undue influence, breach of fiduciary duty, conversion, and fraud. Id. at *2. The beneficiary daughter challenged the probate courts authority to hear the civil actions. The district court concluded it had subject-matter jurisdiction over trust matters and related petitions and the daughter appealed. Id. at *4. The Court of Appeals upheld the district courts determination of subject-matter jurisdiction and cited the Supreme Courts opinion in Janecek. It noted [t]here is no district court which is not also a probate court, and no distinction between the courts. Id. at *5 (citing Estate of Matthews, 558 N.W. 2d 263, 265 (Minn. Ct. App. 1997). However, the Court of Appeals did opine district courts should clarify the scope of trust proceedings. Id. at *9.
Historically, probate courts and district courts were separate in Minnesota with the former having limited jurisdiction over estate matters. However, Minnesota caselaw altered that distinction and probate courts may hear civil claims related to the administration of an estate. For more estate planning advice, contact a knowledgeable Minnesota estate planning attorney.
Minnesota Probate Lawyers
If you need further information on subject matter jurisdiction in a Minnesota probate case, contact Joseph M. Flanders of Flanders Law Firm LLC at612-424-0398.
