In re Estate of KendallAnnotate this Case
The Supreme Judicial Court held that the Estate of Jacqueline Ann Kendall was not required to pay a claim for reimbursement from the Commonwealth's MassHealth program when the estate proceeding was commenced more than three years after Kendall died.
Kendall received MassHealth benefits in the amount of $104,738 and died intestate on August 7, 2014. On May 24, 2018, one of Kendall's heirs filed a petition for late formal testacy and notified MassHealth. MassHealth filed a notice of claim in the estate. At issue was whether the estate was required to pay the MassHealth claim more than three years after Kendall died. The Supreme Judicial Court held (1) Mass. Gen. Laws ch. 190B, 3-803(f) creates an exception for MassHealth to the general limitation on creditor claims laid out in section 3-803(a) but does not create an exception to the ultimate time limit on the personal representative's power to pay claims and creditors' ability to bring claims laid out in Mass. Gen. Laws ch. 190B, 3-108; and (2) therefore, MassHealth's claims were time barred.