In Re: Koepfinger (majority)
Annotate this CaseAppellant Joseph Koepfinger (“Father”) was a nonagenarian and father of several adult children, including Appellee Margaret Koepfinger (“Daughter”). In September 2016, shortly after the death of Father’s wife/Daughter’s mother, Father executed a power of attorney (“POA”), naming Daughter as his agent. The POA gave Daughter the authority to, among other things, create an irrevocable trust for Father; it further provided that Father could revoke the POA but only in writing. Soon after the execution of the POA, tensions began to build between Father and Daughter due to Father’s developing relationship with Madeline Masucci (“Masucci”). In 2017, Father allegedly orally informed Daughter that he revoked the POA and that he executed a new power of attorney, naming his son/Daughter’s brother as his agent. Daughter, however, claimed she was not informed of these events until May of 2018. In the meantime, in April 2018, acting as Father’s agent under the POA, Daughter created an irrevocable trust for Father, placing a substantial amount of his assets into that trust. Daughter named herself as trustee. After Daughter allegedly was informed that Father revoked the POA, she filed a Petition for Declaratory Judgment requesting, in relevant part, judicial declarations that: (1) the 2016 POA was not revoked at the time that she created the trust; (2) the creation and funding of the trust was within her scope of authority under the POA; and (3) the trust is valid. The issue this case presented for the Pennsylvania Supreme Court's review centered on whether a judicial determination that a power of attorney was void ab initio invalidated an irrevocable trust created by the purported agent under the void power of attorney. The orphans’ court answered this question in the affirmative, but the Superior Court reversed. The Supreme Court held that, when a court concludes that a power of attorney is a nullity, any action taken under the auspices of the power of attorney is likewise a nullity. Consequently, the Court vacated the Superior Court’s judgment and reinstated the orphans’ court’s order.
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