On June 16, 2022, the U.S. Court of Appeals for the Sixth Circuit affirmed a District Court decision in favor of Taft clients in a matter involving the unique “probate exception” to federal court jurisdiction.

Taft partners Julia Meister, David Wallace, and Philip Williamson represented clients who had inherited assets from a family member more than 20 years ago. Taft had prevailed in the U.S. District Court for the Northern District of Ohio against a party who was seeking to challenge our clients’ and another entity’s receipt of assets from the administration of the estate by a state probate court. The plaintiff appealed to the Sixth Circuit and Taft represented the appellees.

The plaintiff had attempted to offer posthumous DNA evidence and asserted she was the daughter of the decedent, arguing her entitlement to assets from his much earlier-administered estate. She was unable to establish standing as a heir or to challenge the will because she did not bring an action to establish paternity within the time period required under Ohio law. In addition, the District Court found it lacked subject matter jurisdiction over the plaintiff’s case under the “probate exception” doctrine, made famous by a 2006 U.S. Supreme Court case involving Vickie Lynn Marshall (aka Anna Nicole Smith) and the estate of her husband, petroleum billionaire J. Howard Marshall. That landmark decision outlined the probate exception to federal jurisdiction. The District Court also explained it could not exercise jurisdiction because doing so would interfere with probate administration proceedings that are reserved for state probate courts.

In an opinion written by Chief Judge Jeffrey Sutton, the Sixth Circuit affirmed the District Court’s decision to dismiss the case for lack of standing.

The case is Carroll v. Hill, et al., No. 21-3885 (6^th Cir. 2022).

Julia Meister is a partner in Taft’s Cincinnati office and member of the Litigation and Private Client groups. She heads the firm’s Wealth Transfer Litigation practice. She has first chair bench and jury trial experience and has prevailed for the plaintiff and for the defense in challenges to estate planning documents and fiduciary conduct. 

David Wallace represents clients in cases involving complex business litigation, class action, and shareholder litigation. He has state and federal court experience managing class action, derivative, and multiparty litigation matters concerning a wide variety of issues. He is the Taft Cleveland Litigation chair.

Philip Williamson has briefed appeals in multiple U.S. Courts of Appeals, including the Sixth, Seventh, and Ninth Circuits, as well as state appellate courts in Ohio, Kentucky, and Georgia. He is a partner in Taft’s Cincinnati office.