Dathan A. Griffin v. Christine Pearson, as Personal Representative of the Estate of Martha Harwell Tiller

Summary

The Sixth District Court of Appeal dismissed Dathan A. Griffin’s appeal for lack of jurisdiction. The court held that Griffin lacked standing to challenge admission of the decedent’s 2012 will because he was not an “interested person” under section 731.201(23), Florida Statutes. Griffin was neither a beneficiary, personal representative, nor estate creditor, and his claimed expenditures relating to adverse possession did not give him a sufficient interest in the probate proceeding.

Holdings

1. Griffin was not an interested person under section 731.201(23), Florida Statutes, and therefore lacked standing to participate in Tiller's probate proceeding. A stranger to the estate whose claimed interest consists only of expenditures made after the decedent's death to advance an adverse-possession claim is not an interested person on these facts.
2. The court lacked jurisdiction because Florida Rule of Appellate Procedure 9.170(b) limits review of probate orders to orders that finally determine a right or obligation of an interested person, and Griffin was not an interested person.
3. The court must apply the supremacy-of-the-text principle and interpret the words of section 731.201(23) in context, exhausting relevant textual and structural clues and considering the purpose and subject matter of the proceeding.

Questions Presented

1. Whether Griffin had standing and qualified as an interested person under section 731.201(23), Florida Statutes, to challenge admission of Tiller's 2012 will to probate.
2. Whether the appellate court had jurisdiction under Florida Rule of Appellate Procedure 9.170(b) to review the order overruling Griffin's objection to admission of the will.

Disposition

dismissed