Piazzi

INTRODUCTION

In this probate case, appellant Diane Piazzi petitioned to invalidate trust amendments made by her late mother, Evelyn Piazzi. Diane alleged that Evelyn lacked capacity to amend the trust and that she did so because she was unduly influenced by respondent Gerald Laffey (Evelyn’s nephew) and other relatives. The case was tried to the probate court. The court granted a motion for judgment in Gerald’s favor after Diane’s case-in-chief. We affirm. Diane’s failure to prove her claims is well supported by substantial evidence, and we reject Diane’s other arguments on appeal.

PROCEEDINGS BELOW

A. Diane Petitions to Invalidate the Trust Amendments Due to disabilities, Diane receives means-tested public benefits. In June 1991, Diane’s mother Evelyn created the Revocable Living Trust of Evelyn C. Piazzi. Through special needs trust provisions, the trust expressed Evelyn’s intent that after her death, the trust estate would be used to supplement Diane’s means-tested benefits without disqualifying her from continuing to receive them. In March 1999, Evelyn executed a first amendment to the trust, which deleted the special needs trust provisions and provided for the estate to be…