Leckie

The County of Orange Assessment Appeals Board (the Board) appeals the summary judgment in favor of Bernard A. Leckie, successor trustee of the Charles G. Adams Trust, determining that the creation of a life estate in real property upon Adams’s death was not a change in ownership for purposes of reassessment of property value. We reverse. Leckie appeals the denial of his attorney fees, claiming he is entitled to them because the trial court found in his favor. We reverse the determination of the trial court, rendering the attorney fee issue moot.

Charles Adams lived with Rachel Cordova in his house in Santa Ana for a substantial number of years before his death. They never married. Adams transferred the house to his revocable trust in 1985; pursuant to the trust provisions, a life estate in the house was created for Rachel on his death in 1992. She was then 58 years old. Upon termination of the life estate, the remainder interest will pass equally to two of Adams’s four adult children.

The county assessor determined that the transfer of the life estate was a change of ownership and assessed the house at its full cash value as of Adams’s date of death. Leckie, Adams’s…