Margaret-Mary Hovarth v. Walter R. Craddock

Summary

The Rhode Island Supreme Court held that the Family Court lacked jurisdiction to adjudicate a post-divorce request for an accounting of custodial assets established under the UGMA and UTMA. The court affirmed the denial of the mother's motion, concluding that the UTMA expressly vested jurisdiction in the Probate Court and that the divorce proceedings did not provide an independent basis for Family Court jurisdiction.

Holdings

1. The Family Court lacked jurisdiction over actions brought under the UTMA because the statute expressly defined the relevant court as the probate court and did not confer jurisdiction on the Family Court.
2. The Family Court could not hear the mother's UTMA claims because the daughter had attained the age of majority by the time the Family Court adjudicated the matter, and the mother was not seeking child-support or educational-expense relief under a prior order.

Questions Presented

1. Whether the Rhode Island Family Court had jurisdiction to adjudicate a post-divorce request for an accounting and delivery of custodial property under the Uniform Transfers to Minors Act.
2. Whether the Family Court could exercise jurisdiction because the parties had previously been subject to its divorce and child-custody jurisdiction.
3. Whether the daughter's attainment of majority before adjudication independently precluded the Family Court from hearing the mother's UTMA claims.

Disposition

affirmed