Settlement agreement concerning a trust; A settlement agreement as a binding contract; Whether the agreement’s terms were unambiguous; Whether the agreement’s terms were breached

Holding that the probate court did not err in ruling the trust-related settlement agreement (SA) at issue was (1) unambiguous and (2) not breached, the court affirmed its order denying appellants’ motion for disclosure and enforcement of the SA. They and appellee are siblings. Appellee became the sole successor trustee. The trust was the subject of lengthy litigation. Appellants asserted SA ¶¶ 10 and 11 “irreconcilably conflict and” this created an ambiguity. The court found the “word ‘further’ in ¶ 10 is a temporal adverb indicating administration of the trust after execution of the [SA]. In other words, administration of the trust after the settlement is complete would not involve [appellants]. However, all parties were responsible for their obligations associated with effectuating the [SA] under ¶ 11. These two provisions are complementary, rather than ambiguous.” The court likewise agreed with the probate court that appellee did not breach the SA. The probate court determined the conveyance of the home from the trust to appellee “was necessary ‘in order to complete the agreement between the parties. This was [her] ‘distributed share of the trust assets as a beneficiary,’ while appellants ‘received a [monetary] distribution from the trust.’ It was insufficient for appellants to ‘sign a quit claim deed and then the [SA] was completed.’ The conveyance of the house ‘then triggered the issuance of the K-1s that went to not the trust, but to the qualified trust beneficiaries for capital gains.’ The probate court reasoned, ‘the issuance of the K-1 is an obligation that is a natural result of the implementing of this’” SA. The court found this “interpretation was in keeping with ¶ 11. In appellants’ view, they should receive monetary distributions from the trust, but any responsibility resulting from [appellee’s] distribution—the house—should be borne entirely by [her]. Such an outcome is patently inequitable. The conveyance of the house is a result of the [SA], which funded the monetary distributions conveyed to [appellants]. Appellants fail to comprehend, or recognize, conveyance of the home . . . was integral and necessary for them to receive monetary distributions from the trust, which they recognized as getting ‘what [they] wanted.’ The conveyance resulted in capital gains tax. The probate court properly held the capital gains tax was a natural result of implementing the [SA], and the parties were responsible for their respective obligations associated with the settlement under ¶ 11.”