Holte v. Rigby

Summary

The court held that co-trustees could not withhold the current life beneficiary’s distributions to recover trust income misappropriated by the beneficiary’s deceased father, because his life interest ended at death and the successor beneficiary was not personally liable for his misconduct. It also held that an equitable lien could not secure recovery of money the deceased trustee stole from the grantor’s personal accounts because the deceased had no continuing asset interest to which the lien could attach. The judgment was affirmed in part, reversed in part, and remanded.