Christine E. Aimone v. Benjamin W. Aimone; Benjamin W. Aimone v. Christine E. Aimone

Summary

The Wyoming Supreme Court considered consolidated appeals arising from a dispute over inheritance rights, trust interpretation, and management of family ranch entities. The Court held that Gay Aimone’s trust unambiguously included the grandchildren as beneficiaries and that Christine Aimone breached fiduciary duties owed to the LLC by disputing ownership interests and altering company records before a court determination. The Court reversed in part but concluded that the grandchildren had not established damages with sufficient certainty to recover.

Holdings

1. Gay's Trust was unambiguous and provided that, upon the distribution event occurring after both Gay and Martin had died, living children would take their shares and the shares of children who had predeceased that event would pass per stirpes to their issue. The grandchildren were therefore intended beneficiaries without reformation of the trust.
2. Christine breached her fiduciary duties of loyalty, care, and good faith by disputing Bruce's children's LLC interests, amending LLC tax records, and removing the children from other LLC documentation before a court determined ownership. Because the conduct was intended to benefit Christine and Colleen personally at the expense of the other members, Christine should be removed as manager.
3. Colleen breached her fiduciary duties by advocating an interpretation of Gay's Trust that favored her personally, relying on personal counsel rather than counsel for the trust, failing to deal fairly with all beneficiaries, and failing to distribute the trust or seek court instructions before litigation.
4. Although Christine and Colleen breached fiduciary duties, the Aimone brothers were not entitled to damages because they failed to establish damages to a reasonable degree of certainty after being given an opportunity to do so.
5. The district court did not abuse its discretion by refusing to consider the Aimone brothers' no-contest-clause argument because it was raised months after the judgment and two years after trial, without supporting authority or a proper procedural basis.

Questions Presented

1. Whether the plain language of Gay's Trust made grandchildren beneficiaries when their parent predeceased Martin but not Gay.
2. Whether Christine Aimone breached her fiduciary duties as manager of Martin Aimone Ranch, LLC and should be removed as manager.
3. Whether Colleen Aimone breached her fiduciary duties as trustee of Gay's Trust.
4. Whether the Aimone brothers properly presented their claim that Christine and Colleen violated the trust's no-contest provision.
5. Whether the Aimone brothers proved damages to a reasonable degree of certainty.

Disposition

other