In the Matter of the Medical Assistance Pooled Special Needs Trust of Steven Muller

Summary

The court held that the trustee properly retained the remaining balance in the beneficiary’s pooled special needs trust subaccount after his death and that the trustee’s final report adequately satisfied its accounting obligation. Because the beneficiary’s subaccount terminated at death and the retained funds were already part of the pooled master account, their continued placement there was a permissible distribution rather than an improper expenditure. The court also held that the district court lacked authority in an accounting proceeding to order payment of the retained funds to the state.