The Montana Supreme Court recently ruled on a legal malpractice case involving the estate of Gregory Engellant. The court upheld a lower court's decision in favor of Crowley Fleck, PLLP, and attorney Daniel McLean, who were accused of mishandling estate planning for Engellant. The ruling impacts the Engellant family, particularly Daren Engellant, who claimed that the defendants' actions led to financial losses for Gregory's estate.
This case, filed under docket number DA 24-0485, centers on allegations that Crowley Fleck failed to properly represent Gregory Engellant in estate planning matters. Daren Engellant, acting as the personal representative of his brother's estate, argued that the firm committed malpractice by allowing Gregory to gift shares of the Engellant Ranch Corporation to his niece, Shana Diekhans, without sufficient investigation of his mental capacity. The court's decision is significant as it clarifies the responsibilities of attorneys in estate planning and the validity of wills.
Background
The Engellant family has a long history tied to the Engellant Ranch in Chouteau County, Montana. Gregory Engellant inherited a significant portion of the family business after the deaths of his parents, Arnold and Madaline Engellant. In 1978, Gregory created a holographic will that divided his estate among his nephews, Daren and Kevin, and his niece, Shana.
In 1982, Gregory suffered a traumatic brain injury that limited his ability to manage his affairs. A court appointed his brother Kenneth as his guardian and conservator. In 2012, Gregory sought the assistance of attorney Daniel McLean from Crowley Fleck to update his estate plan. McLean prepared a new will that intended to gift Gregory's shares in the Engellant Ranch Corporation to Shana, who had been actively involved in operating the ranch.
After Gregory's death in 2019, disputes arose regarding the validity of his 2012 will and whether he had revoked it in favor of an earlier will from 1978. Daren Engellant petitioned to probate the 1978 will, claiming that Gregory had expressed a desire to revoke the 2012 will. However, evidence suggested that Daren did not disclose critical information about alternative versions of the revocation document, leading to further legal complications.
The Ruling
The Montana Supreme Court, led by Justice Beth Baker, affirmed the lower court's judgment in favor of Crowley Fleck and McLean. The court ruled that evidence regarding the validity of Gregory's 2012 will was relevant to Daren's claim of malpractice. The court noted, "Whether the 2012 will was valid bears on the extent to which the Estate can be harmed by a stock gift that went precisely where it would have gone upon Gregory’s death under that same will."
The court also addressed Daren's claims of instructional errors and the exclusion of evidence related to Crowley Fleck's settlement agreement with third-party defendants. The court found that the lower court did not abuse its discretion in these matters and that the jury's determination of the 2012 will's validity was appropriate.
Impact
This ruling has significant implications for legal malpractice cases, particularly in the context of estate planning. It underscores the importance of attorneys ensuring that their clients' wills are valid and reflect their true intentions. The court's decision also highlights the complexities involved when multiple wills are in play and the potential for disputes among family members.
For the Engellant family, the ruling means that Daren's claims against Crowley Fleck for malpractice will not proceed, as the court found no damages resulting from the alleged negligence. This outcome could set a precedent for future cases involving estate planning and the responsibilities of attorneys in similar situations.
What's Next
The ruling can potentially be appealed to the U.S. Supreme Court, although it is unclear if the Engellant family will pursue further legal action. The case highlights ongoing issues related to estate planning and the validity of wills, which may lead to additional litigation in the future as family members navigate the complexities of their inheritance.