White v. White

Summary

The Rhode Island Supreme Court affirmed a judgment imposing a constructive trust over funds withdrawn from joint bank accounts by the defendant. The court held that the evidence supported the trial justice’s finding that the accounts were established for convenience only and that the plaintiff did not intend to make an immediate gift of ownership rights to the defendant.

Holdings

1. Robinson v. Delfino does not control where the intent of the living joint owner is directly ascertainable and the account is alleged to have been established for convenience only.
2. The trial justice correctly found that the joint accounts were established for convenience only and that White did not intend to give her daughter immediate present ownership rights.
3. The constructive trust imposed on the funds withdrawn from the joint accounts was properly sustained.

Questions Presented

1. Whether the trial justice clearly erred in finding that the joint bank accounts were established for convenience only rather than as an immediate gift of present ownership rights.
2. Whether Robinson v. Delfino required the court to treat the creation of the joint accounts with rights of survivorship as conclusive evidence of an immediate present joint beneficial ownership interest.
3. Whether the imposition of a constructive trust on the funds withdrawn by the defendant was proper.

Disposition

affirmed