In the Matter of the Medical Assistance Pooled Special Needs Trust of Scott Hewitt

Summary

The court affirmed summary judgment for the trustee, holding that a pooled special needs trust may retain the entire balance of a deceased beneficiary’s subaccount when neither the governing trust documents nor Iowa law limits the amount retained. Because the trustee’s retention terminates the state’s contingent reimbursement interest and winds up the individual subaccount, the trustee need only account for the subaccount activity, the retention, and the proper purpose for retaining the funds, not their eventual use. The court concluded that the trustee’s accounting was adequate.