Glassie v. Doucette, No. 21-1761 (1st Cir. 2022)
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In this case stemming from a lengthy and acrimonious family dispute over the property of Donelson Glassie, whose estate remained in probate in Rhode Island eleven years after his death, the First Circuit reversed the judgment of the federal district court dismissing Plaintiff's claims as barred by the probate exception to federal court jurisdiction, holding that the district court erred.
Plaintiff, Donelson's daughter, brought this action against several family members, including the executor of Donelson's estate, alleging that Defendants were liable to her under the federal Racketeer Influenced and Corrupt Organizations (RICO) laws, 18 U.S.C. 1962, because they formed an enterprise that engaged in a pattern of fraudulent interstate communications and that Defendants breached fiduciary duties owed to her as a minority member of an entity wholly owned by a company in which the estate held a fifty-eight percent interest, and other claims. The district court dismissed all claims. The First Circuit reversed, holding that the district court erred in finding the probate exception applicable to this case.
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