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In re: the Elaine Emma Short Revocable Living Trust Agreement, Dated July 17, 1984. ICA s.d.o., filed 10/24/2024 [ada], 155 Haw. 179. Application for Writ of Certiorari, filed 01/21/2025. S.Ct. Order Accepting Application for Writ of Certiorari, filed 03/17/2025 [ada].

2025-09-08

Summary

Holding. The Court vacated the ICA's affirmance of the probate court's denial of the Cooks' request for attorneys' fees and remanded the case to the probate court for reconsideration following a final decision on the merits.

This case involves a family dispute over whether a trustee could distribute principal from Elaine Emma Short's revocable living trust to her son David, and whether contingent remainder beneficiaries (Elaine's nieces and nephews, the Cooks) could recover their attorneys' fees from the trust. The probate court initially allowed principal distributions and ordered all parties' fees paid from the trust. The Intermediate Court of Appeals reversed the fee award for the Cooks, finding their status as contingent beneficiaries precluded recovery. On remand, the probate court again denied fees, and the ICA affirmed, concluding the denial was independent of a procedural defect.

The Supreme Court held that the ICA erred in affirming the fee denial without first requiring the probate court to resolve the underlying merits in compliance with Hawai'i Probate Rules. The Court clarified that contingent beneficiaries may recover attorneys' fees if their participation advanced the interests of the entire trust, not based solely on their status as contingent beneficiaries. Because the underlying dispute was not finally decided on the merits, the fee determination was premature.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether contingent beneficiaries may recover attorneys' fees from a trust corpus
  • Whether a probate court must enter a Hawai'i Probate Rules Rule 20(a) order before resolving contested matters
  • Whether a trust litigant's participation must be assessed based on their status as contingent beneficiary or on whether their appearance assisted the court in clarifying trustee duties
  • Whether a fee denial can be affirmed as independent of procedural defects when the underlying merits remain unresolved

Procedural posture

The Cooks sought certiorari review of the Intermediate Court of Appeals' affirmance of the probate court's denial of their request for attorneys' fees incurred in challenging the trustee's petition to modify the trust to allow principal distributions.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

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Electronically Filed

Supreme Court

SCWC-XX-XXXXXXX

08-SEP-2025

12:37 PM

Dkt. 23 OP

IN THE SUPREME COURT OF THE STATE OF HAWAIʻI

---o0o---IN THE MATTER OF THE ELAINE EMMA SHORT REVOCABLE

LIVING TRUST AGREEMENT, DATED JULY 17, 1984, AS AMENDED

SCWC-XX-XXXXXXX

CERTIORARI TO THE INTERMEDIATE COURT OF APPEALS

(CAAP-XX-XXXXXXX; CASE NO. 1TR151000165)

SEPTEMBER 8, 2025

RECKTENWALD, C.J., MCKENNA, EDDINS, GINOZA, AND DEVENS, JJ.

OPINION OF THE COURT BY RECKTENWALD, C.J.

I. INTRODUCTION

This case arises from a request for attorneys’ fees

relating to a petition for instructions regarding the

distribution of principal from a trust. Contingent remainder

beneficiaries contested the distributions. We overturned the

probate court’s initial grant of the petition for instructions

because the probate court did not enter an order required under *** FOR PUBLICATION IN WEST’S HAWAI‘I REPORTS AND PACIFIC REPORTER ***

Rule 20(a) of the Hawaiʻi Probate Rules (HPR). 1 On remand, the

probate court again did not enter an HPR Rule 20(a) order and on

subsequent appeal the Intermediate Court of Appeals (ICA) again

remanded.

The contingent remainder beneficiaries seek review of

the probate court’s denial of their motion for attorneys’ fees,

which the ICA affirmed as independent of the probate court’s

failure to enter the HPR Rule 20(a) order. We hold that the

proper test for determining whether a probate court may award

trust litigants attorneys’ fees is whether their appearance

assisted the court in resolving the dispute before it. A

decision on the merits is necessary before determining if an

award of attorneys’ fees is proper. Because the ICA vacated the

circuit court’s decision on the merits in this case, its

affirmance of the probate court’s denial of fees was premature.

1 HPR Rule 20 provides in relevant part:

(a) Assignment. The court by written order may retain a

contested matter on the regular probate calendar or may

assign the contested matter to the civil trials

calendar of the circuit court.

(d) Procedures in Retained Contested Matters. Whenever the

court retains jurisdiction of a contested matter as a

probate proceeding, the court in the order of assignment

may, at the request of the parties, designate and order

that any one or more of the Hawaiʻi Rules of Civil Procedure

and/or the Rules of the Circuit Courts shall be applicable

in such matter.

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Accordingly, we vacate the ICA’s judgment affirming the probate

court’s denial of the motion for attorneys’ fees and remand the

case to the probate court.

II. BACKGROUND

The facts and much of the procedural history are laid

out in In re Elaine Emma Short Revocable Living Trust Agreement

Dated July 17, 1984, as Amended (Short Trust II), 147 Hawaiʻi

456, 465 P.3d 903 (2020). Elaine Emma Short (Elaine) was

married to Clarence Short (Clarence) and they had two sons,

David Short (David) and William Short (William). Id. at 459,

465 P.3d at 906. Elaine’s brother, Leroy Cook, had five

children (collectively, “the Cooks”). Id. In 1984, Elaine

established a revocable living trust (“initial trust”), as did

Clarence (“Clarence’s trust”), for the purpose of providing for

each other, as well as their two sons. Id. Elaine named

Clarence as the trustee of her estate, with David, William, and

First Hawaiian Bank (FHB) as successor trustees. Id.

Article V.B. of the initial trust provided that, if

Elaine was not survived by her spouse, subtrusts would be

created for her sons from which the successor trustee could

distribute principal and income to David and William as needed.

Id. at 459-60 n.2, 465 P.3d at 906-07 n.2. On March 10, 1993,

Elaine amended the trust, including Article V.B.(a), “to provide

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the Successor Trustee with full discretion to withhold

distribution of income to David and William if warranted by the

circumstances[.]” Id. at 460, 465 P.3d at 907. The amended

trust provided only for the distribution of income, and not

principal, from the subtrusts to meet the sons’ needs for

“health, education, support, and maintenance,” as determined by

the Successor Trustee. Id. Additionally, the amended trust

failed to provide for termination of the sons’ subtrusts. Id.

William passed away, unmarried and without children,

on June 8, 1993, and Clarence passed away on April 10, 2010,

both predeceasing Elaine. Id. Elaine became incapacitated in

2005 and passed away on January 3, 2012. Id. David is

unmarried and has no children. Id.

A. Initial Proceedings 2

On August 12, 2015, trustee First Hawaiian Bank (FHB)

filed a petition to modify Elaine’s trust. FHB, through its

petition, sought to:

(1) instruct the trustee that David’s subtrust created

under Amended Article V.B.(a) of Elaine’s Trust terminate

upon the death of David; (2) instruct the trustee that

discretionary distributions of principal may be made from

David’s subtrust; and (3) modify Elaine’s Trust to provide

for a termination date and the discretionary distribution

of principal, by amending Article V.B.(a); and (4) allow

payment of FHB’s attorneys’ fees and costs. In the

2 The Honorable Judge Derrick H.M. Chan presiding.

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petition, FHB listed the Cooks as heirs at law and

contingent beneficiaries under Elaine’s Trust.

Id. at 461, 465 P.3d at 908 (footnote omitted).

In the 2015 probate proceeding, the Cooks contested

the petition. While agreeing that David’s subtrust should

terminate at David’s death, the Cooks opposed FHB’s proposed

modification allowing the distribution of principal to David.

Id. In addition, the Cooks argued that “Elaine’s Trust was not

ambiguous as to the permitted distribution of the principal

. . . and thus FHB’s attempt to change the language of Elaine’s

Trust should be rejected as improper.” Id. Also, the Cooks

sought reimbursement for their attorneys’ fees. Id.

FHB responded, arguing that “its petition properly

sought clarification of its duties under Elaine’s Trust” because

“permitting discretionary distributions of principal to David

would be in furtherance of Elaine’s intent to provide for her

sons and any issue they might have.” Id. at 462, 465 P.3d at

909. Further, FHB argued the trust was ambiguous because, while

it did not explicitly authorize distributions of principal, it

also “did not expressly prohibit such action” either. Id.

Addressing the question of attorneys’ fees, FHB asserted that

“payment of attorneys’ fees to the Cooks from the principal

[w]as a potentially improper use of trust assets for

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non-beneficiaries because the Cooks were contingent

beneficiaries.” Id.

David responded, agreeing with FHB and the Cooks “as

to setting a proposed termination date for Elaine’s Trust” but

siding with FHB over the Cooks “that [David] should receive

discretionary distributions of principal from Elaine’s Trust[.]”

Id. David reasoned that “Elaine’s Trust merely contains an

‘Armageddon clause’ referencing ‘heirs at law,’[ 3] which does not

provide a sufficient basis for the Cooks to frustrate Elaine’s

primary intent to benefit her sons.” Id. at 463, 465 P.3d at

910.

After a hearing on the matter, the probate court

entered an order “modifying Elaine’s Trust to provide for

discretionary payments of principal to David and terminating his

subtrust under Amended Article V.B.(a) and (b) at his death.”

Id. The probate court also concluded that the Cooks were not

entitled to financial information from FHB. Id. Finally, the

probate court “ordered that the attorneys’ fees for all parties

3 An “Armageddon clause” is a trust provision that disposes of the trust corpus “in the (presumably unlikely) event that all of the settlor’s descendants or other individual beneficiaries should fail to survive to the end of the trust term.” Benjamin H. Pruett, Tales from the Dark Side: Drafting Issues from the Fiduciary Perspective, 2011 ABATAX-CLE 1022087, 2011 WL 5827897 (Oct. 27, 2011).

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involved in the proceedings be paid from the principal of

Elaine’s Trust.” Id.

The Cooks appealed the probate court’s judgment and

order, asserting two points of error:

(1) in permitting the Bank to modify Art. V, paragraph B of

the Trust, allowing Bank to invade the Trust corpus to make

discretionary principal distributions; and (2) when it

failed to require Bank to provide financial information to

the Cooks relating to the Trust, including David’s total

income, and David’s income from the Clarence Trust.

In re Elaine Emma Short Revocable Living Tr. Agreement Dated

July 17, 1984, as Amended (Short Trust I), 2019 WL 2417367, at

*4 (App. June 10, 2019) (mem. op.).

David cross-appealed, contending that the probate

court abused its discretion when it granted the Cooks’ request

to have their attorneys’ fees and costs paid from the Trust.

Id.

The ICA affirmed the probate court “in all respects

except as to the grant of the Cooks’ attorneys’ fees and costs

which were to be paid out of the Trust,” which the ICA reversed.

Id. at *12.

The Cooks then sought review by this court, contending

that the ICA erred in the following:

(1) after finding an ambiguity in the trust, weighing

conflicting evidence to determine Elaine’s intent and

ignoring other evidence to resolve the ambiguity without

holding a hearing as required for contested matters under

Hawaiʻi Probate Rules (HPR) Rules 19 and 20; (2) affirming

the probate court’s decision to deny the Cooks any

financial information regarding Elaine’s Trust despite the

trustee’s statutory duty to produce this information; and

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(3) determining that the probate court abused its

discretion in awarding attorneys’ fees and costs to the

Cooks.

Short Trust II, 147 Hawaiʻi at 464, 465 P.3d at 911 (internal

footnotes omitted).

We accepted certiorari. As to the first contention,

we held that the ICA “erred in affirming the probate court’s

Order and judgment instead of remanding the case to the probate

court with instructions to render findings of fact.” Id. at

467, 465 P.3d at 914.

We reasoned that,

The probate court’s written Order in this case allowed FHB

to modify Elaine’s Trust to provide for the distribution of

principal to David. The Order, however, contained no

findings of fact as to whether Amended Article V.B.(a) was

ambiguous. . . . In short, the probate court did not

articulate the factual basis of its ruling.

Id. at 465, 465 P.3d at 912.

Additionally, we addressed the application of HPR Rule

20, which provides, “[t]he court by written order may retain a

contested matter on the regular probate calendar or may assign

the contested matter to the civil trials calendar of the circuit

court.” HPR R. 20(a). We explained that, “[a]lthough the

probate court is not obligated to adopt any and all rules that

the parties request, it must exercise its discretion to do so

‘with regard to what is right and equitable under the

circumstances and the law.’” Short Trust II, 147 Hawaiʻi at 469,

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465 P.3d at 916. By not issuing an HPR Rule 20 order, “the

parties were not provided an opportunity under HPR Rule 20(d) to

request that the probate court adopt [Hawaiʻi Rules of Civil

Procedure] Rule 52 and render findings of fact at the time an

order of retention should have been issued.” Id. We further

reasoned:

[W]hile the probate rules do not specifically require

findings in all contested cases retained by the probate

court, their omission in a dispositional ruling may require

an appellate court to remand the case for the making of

findings to enable the appellate court to meaningfully

review the probate court’s decision.

Id. at 471, 465 P.3d at 918.

Thus, we concluded that we were unable to conduct an

appropriate appellate review due to the “complete absence of

findings by the probate court preclud[ing] us from being able to

determine which facts the court relied upon[,] and which

underlay the court’s modification of Elaine’s Trust.” 4 Id.

As to the second contention, we held that “the ICA

erred in holding that the terms of Elaine’s Trust can supersede

HRS § 560:7-303 [(2006)] to limit which beneficiaries are

entitled to trust and accounts information from the trustee.”

4 In a separate opinion concurring in part and dissenting in part, the minority would have affirmed the ICA as to this question. The dissent argued that our caselaw and the HPR did not require the probate court to enter findings of fact under the circumstances there at issue and, as such, the ICA properly reviewed the extrinsic evidence in the record to affirm the probate court. Short Trust II, 147 Hawaiʻi at 478, 465 P.3d at 925 (Recktenwald, C.J., concurring in part and dissenting in part).

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Id. at 474, 465 P.3d at 921. We explained that HRS § 560:7-303

requires a trustee to “‘keep the beneficiaries of the trust

reasonably informed of the trust and its administration.’

Hawaiʻi law is clear that a trust beneficiary is any person with

a ‘future interest, vested or contingent.’ HRS § 560:1-201

(2006) (emphasis added).” Short Trust II at 472, 465 P.3d at

919. Thus, we concluded that “[w]hile their interest may be

divested if a greater claim arises, this does not mean that the

Cooks are not currently reasonably entitled to accounts

information regarding Elaine’s Trust as provided by HRS § 560:1-201.” Id. at 474, 465 P.3d at 921.

Finally, this court acknowledged but did not reach a

decision regarding the Cooks’ third contention that the ICA

erred in determining that the probate court abused its

discretion in awarding attorneys’ fees and costs to the Cooks.

See id. at 464, 465 P.3d at 911.

Ultimately, we vacated and remanded the proceeding as

follows:

[T]he ICA’s August 1, 2019 Judgment on Appeal is vacated,

except as to its affirmance of the denial of account

information to the Cooks from Clarence’s Trust. The

probate court’s judgment and Order are also vacated except

as to its ruling regarding providing account information

from Clarence’s trust. The case is remanded to the probate

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court for further proceedings consistent with this

opinion.[ 5]

Id., at 475, 465 P.3d at 922.

B. Proceedings on Remand 6

On September 29, 2020, FHB filed a new Petition for

Instructions Regarding Principal Distributions and Attorneys’

Fees, and for Modification of Trust in its capacity as trustee

for the Elaine Short Trust. In its petition, FHB requested that

the probate court:

(a) issue a formal order retaining this matter in the

Probate Court (assuming an objection is filed, which would

make the petition contested under HPR 19); (b) consider the

evidence proffered in this Petition; and (c) render

findings of fact and conclusions of law in Petitioner’s

favor on the unresolved questions. These questions include

whether to modify the Trust to allow distributions of

principal to David and determining whether the Contingent

Remainder Beneficiaries may receive attorneys’ fees from

the Trust.

On March 5, 2021, the probate court entered written

findings of fact and conclusions of law regarding FHB’s

September 29, 2020, Petition for Instructions Regarding

Distributions and Attorneys’ Fees, and for Modification of

Trust. The probate court made the following relevant findings

of fact:

5 Because the Cooks did not challenge in their application for certiorari the ICA’s holding that they were not entitled to accounting information for Clarence’s trust, the Short Trust II court did not address the issue. Short Trust II, 147 Hawaiʻi at 464 n.15, 465 P.3d at 911 n.15.

6 The Honorable Judge R. Mark Browning presiding.

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Contingent Beneficiaries

29. The Trust does not mention the Contingent

Beneficiaries by name and the Contingent Remainder

Beneficiaries will only receive an interest as “heirs-atlaw” if there are no surviving issue of the Settlor

remaining. Had the Settlor intended to provide for the

Contingent Remainder Beneficiaries, she could have left a

specific devise or devised a portion of the trust estate to

the Contingent Remainder Beneficiaries. That the Settlor

did not is indicative of her overarching intent with her

Trust, especially as compared to the specifically stated,

and unquestionably clear, intent to provide for her sons.

30. The Settlor’s primary intent in creating the Trust is

to provide support for her issue. Currently, David is the

Settlor’s last surviving issue. If the Trustee were to

distribute income only to David, David would not be the

primary beneficiary of the Trust. Instead, the Contingent

Remainder Beneficiaries, the Settlor’s heirs at law, would

primarily benefit from the trust estate because the

Settlor’s heirs at law would receive the bulk of the trust

estate. It does not appear that the Settlor intended such

a result.

31. The Petitioner included a declaration from Carol Short

with the Petition. Carol Short is the surviving spouse of

Robert Short, who was the brother-in-law of the Settlor.

Carol Short knew Elaine and Clarence for 40 years and was

in regular contact with Settlor before her death. Among

other things, Carol Short attests that Elaine never

mentioned the Contingent Remainder Beneficiaries. The

Court finds this declaration to be both credible and

persuasive. Based on this declaration, the Settlor was not

close to her nieces and nephews or extended family members.

Prior to the death of the Settlor, there had been little to

no contact between the Settlor and the Settlor’s siblings,

nieces or nephews in decades.

32. The Settlor’s nieces and nephews are beneficiaries, as

an alternative, only if there are no remaining issue of the

Settlor then surviving. Based on these facts, in all

likelihood, the Settlor did not anticipate that William

would predecease the Settlor without issue, and that David

would also have no issue.

33. The Court rejects the declarations submitted by the

Contingent Remainder Beneficiaries. The declarations are

self-serving, looking to establish extrinsic evidence of a

“warm relationship” between the Contingent Remainder

Beneficiaries and Settlor. The Court finds these

declarations not credible and also unpersuasive. Even

considered on their merits, these declarations are

insufficient to overshadow Settlor’s intent as to her

Trust, as evidenced by the text of the Trust itself.

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34. Beyond these general considerations, the Court also

disregards the Declaration of Marcia M. Kleeberger because

it is based on hearsay, not personal knowledge. Even if

this declaration were based on personal knowledge, it does

not offer sufficient evidentiary basis to conclude that

Elaine had such a close and warm relationship with the

Contingent Remainder Beneficiaries such that Elaine

intended her Trust to benefit the Contingent Remainder

Beneficiaries over her own children and grandchildren. Nor

do the terms of the Trust support such a conclusion.

35. The Contingent Remainder Beneficiaries also offer the

Declaration of Susan Kay Cook Galvin dated September 15,

2015 (the “Galvin I Declaration”) and the Supplemental

Declaration of Susan Kay Cook Galvin dated October 29, 2015

(the “Galvin II Declaration”) as evidence of the alleged

warm and close relationship between Elaine and the

Contingent Beneficiaries. The Court concludes that the

facts offered in these declarations (regarding significant

life events in the 1960s, 1970s, 1980s, and 1990s) do not

offer sufficient evidentiary basis to conclude that Elaine

had such a close and warm relationship with the Contingent

Remainder Beneficiaries such that Elaine intended her Trust

to benefit the Contingent Remainder Beneficiaries over her

own children and grandchildren. Nor do the terms of the

Trust itself support such a conclusion.

36. On this point, the Court notes that Elaine created the

original Trust instrument on July 17, 1984, and amended the

Trust on March 10, 1993. Elaine also executed the Last

Will and Testament of Elaine Emma Short on September 4,

1979, which was probated in Elaine’s probate proceeding, P.

No. 13-1-0671. According to the Galvin II Declaration,

Elaine visited the Contingent Remainder Beneficiaries

several times prior to the creation of the Trust, and

during the period she created and amended her Trust.

During this same time period, Elaine failed to devise a

portion of the trust estate to the Contingent Remainder

Beneficiaries and failed to specifically name any of the

Contingent Remainder Beneficiaries in any of her estate

planning documents. Additionally, Elaine failed to provide

for the Contingent Remainder Beneficiaries in any respect

in Elaine’s Will, even though Elaine and Clarence visited

the Contingent Remainder Beneficiaries in the years prior

to signing Elaine’s Will in 1979. Contingent Remainder

Beneficiaries’ argument that she must have intended to

provide for them due to the “warm relationship,” is

therefore unpersuasive.

37. As to Contingent Remainder Beneficiaries’ request for

attorneys’ fees, the Court finds that their status cannot

presently be ascertained. Currently, the only known and

ascertained beneficiary of the Trust is David. At this

time, the remainder beneficiaries cannot be ascertained.

If David were to have issue at his death, the Contingent

Remainder Beneficiaries would cease from being

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beneficiaries of the Trust. Additionally, if any of the

Settlor’s current heirs at law fail to survive David, they

would no longer be contingent remainder beneficiaries of

the Trust.

38. To the extent these findings of fact should be

construed as conclusions of law, they shall be so

construed.

(Emphasis added.)

The probate court also concluded that the Cooks were

not entitled to payment of their attorneys’ fees out of the

trust. Relying on Von Holt v. Williamson, 23 Haw. 245, 248-249

(Haw. Terr. 1916), where this court held “It is well established

that fees of counsel for a litigant whose interest is contingent

cannot be allowed out of the trust fund,” the probate court

concluded that “the payment of attorneys’ fees and costs for the

Contingent Remainder Beneficiaries, relating to the 2015

Petition, the appeal of the 2015 Petition, and this Petition,

are not properly payable from the Trust.” Further, relying on

In re Estate of Campbell, 46 Haw. 475, 522, 382 P.2d 920, 953

(1963), for the proposition that “a beneficiary may be awarded

attorneys’ fees and costs from a trust or estate only where the

beneficiaries’ participation in the case advances the interest

of all beneficiaries,” the probate court concluded that “the

Contingent Remainder Beneficiaries’ position was self-serving

and clearly did not benefit the interests of all beneficiaries.

Accordingly, the Contingent Remainder Beneficiaries’ request for

attorneys’ fees and costs is denied.”

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Therefore, the probate court ordered: “The Contingent

Remainder Beneficiaries are not entitled to the payment of their

attorneys’ fees incurred in connection with this Petition and

the Petition for Instructions Regarding Distribution and

Termination, and for Modification of Trust filed in herein [sic]

on August 12, 2015[.]” Judgment on the order was filed on

April 6, 2021.

The Cooks appealed the probate court’s April 6, 2021,

judgment. In their opening brief on appeal, the Cooks asserted

three points of error:

(A) The court erred in permitting Trustee First Hawaiian

Bank to modify subparagraph B of Article V of the trust,

allowing Trustee First Hawaiian Bank to invade the Trust

corpus to make discretionary principal distributions.

(B) The court erred when it resolved disputed issues of

material fact without an evidentiary hearing.

(C) The court erred in refusing to consider an award of

attorneys’ fees to the Remainder Beneficiaries where they

were made parties to the proceeding in order to bind all

remainder beneficiaries.

Relying on Graham v. Washington University, 58 Haw.

370, 569 P.2d 896 (1977), the Cooks argued that “[t]he probate

court should have held an evidentiary hearing to fairly resolve

. . . disputed issues of material fact rather than picking and

choosing what extrinsic evidence it intended to credit.” They

also argued that the standard in summary judgment cases should

have been applied in viewing underlying facts in the record “in

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the light most favorable to the party opposing the motion.” Id.

at 374, 569 P.2d at 899 (citation omitted).

Next, the Cooks argued that remainder beneficiaries

should not be precluded from receiving an award of fees from the

trust. The Cooks relied on Bishop Trust Co. v. Jacobs, 36 Haw.

686, 691 (Haw. Terr. 1944), and Valentin v. Brunette, 26 Haw.

498, 499 (Haw. Terr. 1922), for the proposition that probate

courts have discretion to award fees upon determining the

remainder beneficiaries’ position was helpful to resolve an

ambiguity in the trust and that such was the case here.

The Cooks further argued that, under In re Estate of

Campbell, recovery of fees by all parties is permitted “when

litigation is in advancement of, and not in opposition to, the

interests of all the beneficiaries of a trust.” 46 Haw. at 522,

382 P.2d at 953. The Cooks contended that their participation

in the litigation was to the benefit of all parties involved,

“including any unascertained beneficiaries - Elaine’s

descendants - who may benefit from her Trust in the future,” by

“ensur[ing] the Trust is administered properly” for the benefit

of all potential beneficiaries, including issue David may have

in the future.

The ICA entered a Summary Disposition Order on

October 25, 2024.

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The ICA determined that the probate court failed to

follow this court’s direction in Short Trust II because the

probate court again decided the issue without first issuing an

HPR Rule 20(a) order. Therefore, the ICA vacated the probate

court’s findings of disputed facts because the probate court’s

failure to enter an HPR Rule 20(a) order was structural error

and “[t]his structural error was a departure from the supreme

court’s mandate, and requires another remand of the contested

matter.”

As is relevant to this appeal, the ICA then concluded

that the Cooks’ request for attorneys’ fees to be paid from

Trust principal “arises independent of the probate court’s

failure to enter an HPR Rule 20(a) order.” Aside from

acknowledging that there was no law of the case relevant to this

issue, the ICA did not further explain its reasoning and cited

no authority in support of its conclusion that the two issues

arise independent of each other.

Addressing the issue of attorneys’ fees, the ICA

relied on this court’s statement in Von Holt that “[i]t is well

established that fees of counsel for a litigant whose interest

is contingent cannot be allowed out of the trust fund” and

concluded that “[t]he Cooks are at most contingent remainder

beneficiaries of Elaine’s Trust.” 23 Haw. at 248-49.

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The ICA recognized an exception to the rule requiring

parties to bear their own fees and costs when “the party

advances ‘the interests of all beneficiaries of a trust.’”

(Quoting In re Estate of Campbell, 46 Haw. at 522, 382 P.2d at

953.) The ICA reasoned that the Cooks did not fall under the In

re Estate of Campbell exception because they “tried to advance

their own interests, which were opposed to those of David, the

primary trust beneficiary.”

Thus, the ICA concluded that “[t]he probate court

applied the correct Hawaiʻi law. It did not abuse its discretion

by following the law and denying attorneys[’] fees to the

Cooks.” Ultimately, the ICA affirmed the probate court only as

to the denial of attorneys’ fees and otherwise vacated and

remanded the case for resolution of the contested matters

following entry of an HPR Rule 20 order, provided that “[o]n

remand, the probate court may assign the contested matter to the

circuit court civil trials calendar under HPR Rule 20(b) if the

probate court considers it appropriate.”

The Cooks then sought certiorari review of the ICA’s

affirmance of the probate court’s denial of attorneys’ fees,

which this court granted. In their application for writ of

certiorari, the Cooks present two related questions:

(1) Whether the ICA gravely erred when it affirmed the

probate court’s decision to deny a fee award made by a

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prior probate court without requiring the entry of an HPR

Rule 20(a) order.

(2) Whether the ICA gravely erred in affirming the probate

court’s reversal of the prior probate court’s award of fees

where the Trustee served the Remainder Beneficiaries with

process to make them parties to the proceeding to bind them

and all remainder beneficiaries and where the Remainder

Beneficiaries were successful in requiring the Trustee to

provide financial information for the benefit of all

beneficiaries and where material questions of fact remain

regarding the Settlor’s intent in establishing and amending

the Trust.

III. STANDARD OF REVIEW

“This court reviews a lower court’s award of

attorneys’ fees for abuse of discretion.” In re Tr. Agreement

Dated June 6, 1974, 145 Hawaiʻi 300, 309, 452 P.3d 297, 306

(2019).

The trial court abuses its discretion if it bases its

ruling on an erroneous view of the law or on a clearly

erroneous assessment of the evidence. In other words, an

abuse of discretion occurs where the trial court has

clearly exceeded the bounds of reason or disregarded rules

or principles of law or practice to the substantial

detriment of a party litigant.

Id. at 310, 452 P.3d at 307 (citation and quotation omitted).

IV. DISCUSSION

The Cooks seek an award of attorneys’ fees and costs

in both the initial probate proceedings and now in the

proceedings on remand.

As discussed below, we vacate the ICA’s affirmance of

the probate court’s denial of attorneys’ fees. We do so because

the determination that the Cooks’ participation in the

litigation was not in the interest of the trust and all its

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beneficiaries was premature in the absence of a decision on the

merits of the underlying issue.

A. The ICA Erred in Affirming the Probate Court’s Denial of

the Cooks’ Attorneys’ Fees Without Requiring the Entry of

an HPR Rule 20(a) Order

The probate court’s denial of the Cooks’ attorneys’

fees is reviewed for abuse of discretion, and will only be set

aside when the court “clearly exceeded the bounds of reason or

disregarded rules or principles of law or practice to the

substantial detriment of a party litigant.” In re Tr. Agreement

Dated June 6, 1974, 145 Hawaiʻi at 310, 452 P.3d at 307.

This court held in Short Trust II that

when a case is contested the probate court must, through a

written order, either assign the case to the circuit court

or retain it. HPR Rule 20(a). . . . [I]f the probate

court retains the case, the probate court “in the order of

assignment may, at the request of the parties, designate

and order that any one or more of the Hawaiʻi Rules of Civil

Procedure and/or the Rules of the Circuit Courts shall be

applicable in such matter.” HPR Rule 20(d). Although the

probate court is not obligated to adopt any and all rules

that the parties request, it must exercise its discretion

to do so “with regard to what is right and equitable under

the circumstances and the law.” Booker v. Midpac Lumber

Co., 65 Haw. 166, 172, 649 P.2d 376, 380 (1982) (quoting

Langnes v. Green, 282 U.S. 531, 541, 51 S.Ct. 243, 75 L.Ed.

520 (1931)).

147 Hawaiʻi at 468-69, 465 P.3d at 915-16 (emphasis added)

(footnotes omitted).

The ICA correctly noted that we did not reach the

question of attorneys’ fees in Short Trust II, and that,

accordingly, “there is no law of the case on this issue.” The

question now before this court is whether the denial of fees

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could be properly entered independent of an HPR Rule 20(a)

order. The Cooks argue it cannot because “[a] full and complete

record of the facts of the dispute, the roles of the parties

involved and the intent of the settlor need to be ascertained

before a decision on fees is appropriate in this contested

matter.” 7 FHB and David counter that factual findings are not

necessary as the award of attorneys’ fees is a question of law. 8

Because, as discussed below, the probate court could

not properly conclude that the Cooks’ “position was self-serving

and clearly did not benefit the interests of all beneficiaries”

without first reaching the merits of the case in a manner

consistent with the dictates of HPR Rule 20, the denial of the

Cooks’ fees was not “independent of the probate court’s failure

to enter an HPR Rule 20(a) order.” The ICA therefore erred when

it remanded the case but left the probate court’s denial of fees

intact. Thus, we remand the issue of attorneys’ fees to the

7 The Cooks also contend that the standard in summary judgment cases should apply here. The Cooks rely on Graham, 58 Haw. at 370, 569 P.2d at 896, where this court remanded for further proceedings a case where the trial court erroneously excluded extrinsic evidence of the testator’s intent. Graham is inapt: there, the probate court had granted a motion for summary judgment, where inferences should properly be drawn in favor of the nonmoving party, whereas here the probate court denied a motion for attorneys’ fees, which is reviewed for abuse of discretion.

8 Both FHB and David also contend that this issue is waived because the error was not preserved below. However, given that the Cooks raised the need for an evidentiary hearing at the first opportunity, this issue is not waived.

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probate court to be decided anew in light of a disposition in

compliance with the HPR.

That the Cooks have failed to identify with any

specificity what further evidence could have been adduced at an

evidentiary hearing does not necessitate another outcome. Here,

remand is required so that the probate court can finally decide

the threshold question of whether FHB, as trustee, may properly

distribute principal to David during his lifetime. Only then

may the probate court properly determine if the Cooks’

participation was in the best interest of the trust, for

example, by finding that their participation, “with their

conflicting claims, their evidence and their arguments, was of

assistance to the court in its determination of the duty of the

trustees.” Valentin, 26 Haw. at 498.

B. The Proper Inquiry for Determining Whether a Trust

Litigant’s Participation Advanced the Interests of All the

Beneficiaries of the Trust is Whether the Party’s

Appearance Assisted in Clarifying the Duties of the Trustee

in the Face of an Ambiguity, Which Requires a Determination

on the Merits of the Ambiguity

In Short Trust II, we did not reach whether the Cooks

were entitled to fees despite noting that the question was

presented before this court. Short Trust II, 147 Hawaiʻi at 464,

465 P.3d at 911 (“In their application for writ of certiorari,

the Cooks contend that the ICA gravely erred in the following:

. . . (3) determining that the probate court abused its

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discretion in awarding attorneys’ fees and costs to the

Cooks.”). Nor was the issue addressed in the opinion concurring

and dissenting in part. See id. at 475-78, 465 P.3d at 922-25

(Recktenwald, C.J., concurring and dissenting in part). When we

vacated the ICA’s August 1, 2019, Judgment on Appeal and vacated

the probate court’s December 16, 2015, judgment and order, we

implicitly vacated the probate court’s award of attorneys’ fees

to all parties, including the Cooks. Id. at 475, 465 P.3d at

922. With no law of the case, we address this question anew.

This court has adopted a two-step test to determine

whether a party in trust litigation may recover attorneys’ fees:

In summary, the first question in this type of case is

whether the proceeding was for the benefit of the estate

and in the interest of all parties concerned. If it was

“the trust estate should bear the costs and expenses,

including a reasonable attorney’s fee, of all parties

affected and brought before the court.” The next question,

however, is: To what part of the estate should such

expenses be charged? That depends upon the circumstances

of each individual case. “Where the suit affects the

corpus it is reasonable and proper that the corpus should

bear such expenses. Likewise where the suit affects the

income generally the general income should bear such

expenses. If it affects both the corpus and the general

income it should be prorated accordingly.” When “neither

the corpus of the trust estate nor the general income

accrued or to accrue therefrom was affected” then the

particular fund affected should bear the expenses of the

suit.

In re Estate of Campbell, 46 Haw. at 523-24, 382 P.2d at 954

(quoting Wodehouse v. Robinson, 27 Haw. 602, 603 (Haw. Terr.

1923)).

Trust litigation, like other civil litigation, follows

the American rule when it comes to attorneys’ fees: “The general

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rule is that each party to litigation must pay his own counsel

fees, in the absence of an agreement or statutory authority for

recovery thereof.” Id. at 522, 382 P.2d at 953. However, this

court has recognized an exception to this general rule: “when

litigation is in advancement of, and not in opposition to, the

interests of all the beneficiaries of a trust, counsel fees may

be allowed to litigants out of the estate.” Id.

Our early caselaw held contingent beneficiaries were

not entitled to attorneys’ fees from the “trust fund.” E.g.,

Von Holt, 23 Haw. at 247-48. In Von Holt, the court resolved a

dispute between the testator’s daughter and granddaughter

concerning entitlement to income from a trust estate that

constituted a resulting trust in favor of the daughter. 23 Haw.

at 245. The parties then sought attorneys’ fees from the corpus

of the trust estate. Id. at 245-46. This court characterized

the case as

a friendly controversy between the daughter and

granddaughter as to which of them the said income shall go

during the life of the daughter . . . and that the trustee

appears as a disinterested party, taking sides neither with

the mother nor the infant, and that the controversy does

not involve the principal trust.

Id. at 246.

This court held that neither party was entitled to

attorneys’ fees from the trust estate under the facts of the

case. Id. at 247. Regarding the daughter, whom the trial court

had determined was entitled to the income, the Von Holt court

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explained that she was not entitled to attorneys’ fees from the

corpus because “the cost of the suit must be borne by the

particular fund concerning which the suit arose.” Id. at 248

(quoting 2 Perry on Trusts § 903a (6th ed.)). Thus, because the

suit concerned the income from the trust estate, the daughter

was not entitled to attorneys’ fees from the corpus of the trust

estate, but only from its income, to which she was already

entitled. See id. at 247-48

Regarding the granddaughter, a contingent beneficiary,

this court adopted the test established in Hobbs v. McLean, 117

U.S. 567 (1886), that “the litigation must be in advancement of,

and not in opposition to, the interest of all the beneficiaries

or no allowance of counsels’ fees out of the trust fund will be

made.” Von Holt, 23 Haw. at 248. Nevertheless, this court held

that the granddaughter was not entitled to fees from the corpus

of the trust estate because “[i]t is well established that fees

of counsel for a litigant whose interest is contingent cannot be

allowed out of the trust fund.” Id. The Von Holt court

distinguished an earlier case, Fitchie v. Brown, 19 Haw. 415

(Haw. Terr. 1909), where this court “authoriz[ed] the payment of

the fees of counsel to the various claimants in this case out of

the corpus of the trust estate.” Von Holt, 23 Haw. at 248. The

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court noted that Fitchie involved exceptional circumstances 9 and

concluded that that case was not “an authority generally for the

payment of counsels’ fees for diverse claimants to a particular

fund out of the principal trust fund.” Id.

Subsequently, this court’s analysis shifted away from

a categorical prohibition on awarding attorneys’ fees for

contingent beneficiaries. As discussed above, in In re Estate

of Campbell, this court stated the rule that “when litigation is

in advancement of, and not in opposition to, the interests of

all the beneficiaries of a trust, counsel fees may be allowed to

litigants out of the estate.” 46 Haw. at 522, 382 P.2d at 953.

However, absent provisions to the contrary, the distribution of

attorneys’ fees from the corpus is only permissible when the

corpus is in controversy. Id. at 523-24, 382 P.2d at 953-54.

Thus, the In re Estate of Campbell court explained:

Moreover, even when construction of an ambiguous will is

involved that does not always warrant payment of attorneys’

fees out of corpus as distinguished from income. When the

controversy is in regard to the enjoyment of the income and

the litigants have no interest in the corpus or have only a

9 The Von Holt court characterized the Fitchie case as follows:

In a contest concerning the construction of a will it is

only under exceptional circumstances that the estate of a

decedent should bear the expenses of an unsuccessful appeal

from a decree of this court. . . . The question involved

in their appeal, however, was novel and important and the

amount involved was very large.

Von Holt, 23 Haw. at 248.

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contingent interest, no fee is allowable out of corpus.

Von Holt v. Williamson, 23 Haw. 245. In such case the

income or share thereof the disposition of which is in

controversy should bear the expenses of the suit.

Wodehouse v. Robinson, supra, 27 Haw. 602. And even when

the right to the corpus is in litigation, a fee may not be

paid out of the corpus when the time for distribution has

not been reached and such payment would reduce the income

of the life tenant who has no interest in the controversy.

Bishop Trust Co. v. Cooke Trust Co., supra, 39 Haw. 641,

651 [(Haw.Terr. 1953)].

Id. at 523, 382 P.2d at 953.

Thus, under In re Estate of Campbell, a contingent

beneficiary is limited to recovery from the trust’s income only

if “the controversy is in regard to the enjoyment of the

income.” Id. Here, the dispute does not involve trust income,

but rather distributions from the corpus. As such, In re Estate

of Campbell would not bar the Cooks’ entitlement to an award of

attorneys’ fees, provided its two part-test is satisfied. See

id. at 523, 382 P.2d at 954.

This shift in approach, permitting recovery from the

portion of the trust at issue in the case, as exemplified by In

re Estate of Campbell, is consistent with an analysis for which

the operative question is not the type of interest held by the

litigant, but rather the purpose of the litigant’s action, i.e.,

whether it benefited the trust as a whole. This trend toward

focusing on the purpose of the action, rather than the interest

held by the litigant, was codified in the 2018 Uniform Trust

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Code (UTC), which the Hawaiʻi legislature adopted in 2021. 10 2021

Haw. Sess. Laws Act 32 at 55-93. The UTC which provides in

relevant part:

In a judicial proceeding involving the administration,

interpretation, or validity of a trust, the court may award

reasonable attorney’s fees, costs, and expenses to any

party to the trust who has acted in the best interest of

the trust as a whole, to be paid by another party or from

the trust that is the subject of the controversy.

HRS § 554D-1004(a) (Supp. 2022) (emphasis added).

This position is also consistent with the approach

announced in Comment D to § 88 of the Restatement (Third) of

10 The Cooks do not argue that UTC governs the resolution of this appeal; instead, the Cooks assert that their interpretation of the law “is consistent with the [UTC], which has been in effect since January 1, 2022.” David counters that the UTC “is not application [sic] to this case” because “[t]his proceeding was originally commenced in 2015” and, under HRS § 554-1104(2) (eff. Jan. 1, 2022), “[the UTC] applies to all judicial proceedings concerning trusts commenced on or after January 1, 2022.”

Although the UTC was adopted after this proceeding was commenced, the UTC was given retroactive application through HRS § 554D-1104(3), which provides:

This chapter applies to judicial proceedings concerning

trusts commenced before January 1, 2022, unless the court

finds that application of a particular provision of this

chapter would substantially interfere with the effective

conduct of the judicial proceedings or prejudice the rights

of the parties, in which case the particular provision of

this chapter shall not apply and the superseded law

applies[.]

The probate court proceedings under review here were held prior to the enactment of the UTC. Thus, it would prejudice the parties to apply the new HRS § 554D-1004(a) to an appeal from those proceedings, which were decided under prior law. We express no opinion on the retroactive applicability of the provision on remand.

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Trusts, 11 which provides that “[a] court may, in the interest of

justice, make an award of costs from the trust estate to a

beneficiary for some or all of his or her attorney fees and

other expenses.” Restatement (Third) of Trusts § 88 cmt. D

(Am. L. Inst. 2007).

Under both the UTC and the Restatement (Third) of

Trusts, a contingent remainder beneficiary may properly be

awarded attorneys’ fees if they acted “in the best interest of

the trust as a whole.” See HRS § 554D-1004(a); Restatement

11 Section 88 of the Restatement (Third) of the Trusts, “Power to Incur and Pay Expenses,” provides, “A trustee can properly incur and pay expenses that are reasonable in amount and appropriate to the purposes and circumstances of the trust and to the experience, skills, responsibilities, and other circumstances of the trustee.” Comment D to § 88 provides in relevant part:

A court may, in the interest of justice, make an award of

costs from the trust estate to a beneficiary for some or

all of his or her attorney fees and other expenses.

Ordinarily, however, awards of this type are limited to

situations in which the beneficiary's participation in the

proceeding is beneficial to the trust, usually either

because of a recovery that benefits the trust’s

beneficiaries generally (rather than merely the beneficiary

in question) or by clarifying a significant uncertainty in

the terms of the trust.

T[rustee] petitions the court for instructions to clarify

uncertainties in the meaning of certain distributive

provisions of the trust. The court found that there was

need to clarify the provisions, which it concluded were

ambiguous, and admitted extrinsic evidence that led to

interpretations clarifying the uncertainties. The court

may award appropriate costs to a group of beneficiaries

who, in good faith, urged a reasonable but unsuccessful

interpretation, as well as to the side that prevailed.

(Emphasis added.)

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(Third) of Trusts § 88. As this court emphasized in Short Trust

II, “Hawaiʻi law is clear that a trust beneficiary is any person

with a ‘future interest, vested or contingent.’” 147 Hawaiʻi at

472, 465 P.3d at 919 (quoting HRS § 560:1-201 (2006) (emphasis

added)). Thus, the UTC and the Restatement (Third) no longer

recognize the distinction made between classes of beneficiaries

for purposes of awarding reasonable attorneys’ fees. HRS

§ 554D-1004(a) (providing “the court may award reasonable

attorney’s fees, costs, and expenses to any party to the trust

who has acted in the best interest of the trust as a whole”)

(emphasis added); Restatement (Third) of Trusts § 88 cmt. D

(permitting award of attorneys’ fees to beneficiaries when “in

the interest of justice”). Thus, if decided under the UTC, the

Cooks could properly be awarded attorneys’ fees if the probate

court found they “act[ed] in the best interest of the trust as a

whole.” See HRS § 554D-1004(a). While not controlling here,

the evolution of the law in the UTC provides persuasive support

for a more liberal approach to awarding attorneys’ fees in this

context.

Courts have found resolving ambiguity in the trust to

be in the interest of the trust, In re Estate of Campbell, 46

Hawaiʻi at 522, 382 P.2d at 953 (noting that “fees have been

allowed and charged to corpus when the construction of an

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ambiguous will was involved”), particularly when the issues

presented are questions of first impression clarifying a

trustee’s duties, Valentin, 26 Haw. 498. For example, in

Valentin, trustees made life-tenants and remainder beneficiaries

of the estate parties to a suit seeking instructions as to

whether various expenditures should be paid out of the estate’s

principal or income. 26 Haw. at 498. This court held that

“[u]nder these circumstances the case falls within the rule laid

down, under somewhat conflicting authorities elsewhere, in Evans

v. Garvie, 23 Haw. 694 [(Haw. Terr. 1919),]” that the parties’

attorneys’ fees could properly be paid out of the corpus of the

estate. Valentin, 26 Haw. at 498. The Valentin court reasoned

that, as questions of first impression,

[t]he appearance of the life-tenants and the remaindermen

was made necessary by the uncertainty of the trustees as to

their duty in the premises and by their petition for

instructions. The appearance of these parties, with their

conflicting claims, their evidence and their arguments, was

of assistance to the court in its determination of the duty

of the trustees. In other words, the proceeding was for

the benefit of the estate and in the interest of all

parties concerned.

Id.

Evans, the case relied upon by the Valentin court,

involved a dispute over the apportionment of “extraordinary”

stock dividends between a mother, who was entitled to income

from the trust during her lifetime, and her son, who was

entitled to half of the estate, provided he survived to the age

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of 21, with the other half going to the mother’s heirs at her

passing. 23 Haw. at 695. This court again reasoned that

attorneys’ fees were warranted because “[i]t was an open

question in this jurisdiction, and the decisions elsewhere are

inharmonious.” Id. at 694. Thus, this court concluded that

“[t]he submission of the matter to this court was, therefore, a

proceeding for the benefit of the estate and in the interests of

all the parties concerned.” Id. at 695.

Interestingly, the Evans court distinguished that case

from Von Holt, where this court held that “[i]t is well

established that fees of counsel for a litigant whose interest

is contingent cannot be allowed out of the trust fund.” Von

Holt, 23 Haw. at 248. The Evans court explained:

The circumstances of this case are different from those

involved in Von Holt v. Williamson, . . . where the

successful party established a right to certain income by

way of a resulting trust, and in which claims of counsel

for fees were disallowed. The decision in that case is

consistent with the view that where litigation is in

advancement of, and not in opposition to, the interests of

all the beneficiaries of a trust counsel fees may be

allowed to be paid out of the corpus of the trust fund.

23 Haw. at 695.

Under our caselaw, the proper inquiry when determining

if a trust litigant’s participation advanced the interests of

all the trust beneficiaries requires a determination on the

merits, followed by a determination of whether the litigant’s

appearance assisted in clarifying the duties of the trustee in

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the face of an ambiguity. See Valentin, 26 Haw. at 498 (“The

appearance of these [adverse] parties, with their conflicting

claims, their evidence and their arguments, was of assistance to

the court in its determination of the duty of the trustees.”).

Because the probate court’s determination of the merits of the

case was vacated by the ICA due to its failure to enter an HPR

Rule 20(a) order, the probate court’s denial of attorneys’ fees

must also be vacated.

C. The Circuit Court Abused Its Discretion in Denying the

Cooks Attorneys’ Fees and Costs Because It Based Its

Decision on an Erroneous Statement of Law

We address the probate court’s reasoning in denying

the Cooks attorneys’ fees solely to provide guidance to the

probate court on remand. We conclude that the probate court

based the denial on an erroneous view of the law. See In re Tr.

Agreement Dated June 6, 1974, 145 Hawaiʻi at 309, 452 P.3d at 306

(quoting Chun v. Bd. of Tr. of Emp. Ret. Sys., 106 Hawaiʻi 416,

431, 106 P.3d 339, 354 (2005) (“An abuse of discretion occurs

when a trial court ‘has clearly exceeded the bounds of reason or

has disregarded rules or principles of law or practice to the

substantial detriment of a party litigant.’”)).

In its findings of fact and conclusions of law, the

probate court concluded that the Cooks were not entitled to

attorneys’ fees because (1) the Cooks are contingent remainder

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beneficiaries and (2) the Cooks’ position “did not benefit the

interests of all beneficiaries.” Specifically, regarding the

award of attorneys’ fees to contingent remainder beneficiaries,

the probate court concluded that, under Von Holt, fees were not

permissible.

As discussed above, the correct inquiry for the

probate court is not whether the party-litigant is a contingent

remainder beneficiary but rather whether their position was in

the best interest of the trust as a whole. See Valentin, 26

Haw. at 498; In re Estate of Campbell, 46 Haw. at 522, 382 P.2d

at 953. Thus, the probate court’s conclusion of law was

erroneous.

Further, as a separate basis for its denial, the

probate court concluded the Cooks’ position “did not benefit the

interests of all beneficiaries” because it found that the Cooks’

declarations were self-serving. In reaching this conclusion,

the probate court again applied the incorrect standard.

The proper inquiry for determining whether a trust

litigant’s participation advanced the interests of all the

beneficiaries of the trust includes whether the party’s

appearance assisted in clarifying the duties of the trustee in

the face of an ambiguity. See Valentin, 26 Haw. at 498. The

Cooks’ position that distributions of trust principal would be

inappropriate effectively advocated for maintaining the status

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quo, with distributions being limited to the income. The

probate court did not address whether this position was in the

best interest of the trust. The probate court also did not

address whether the Cooks’ position would have benefited David’s

issue, should he have children, and was thus in the interest of

the trust as a whole. See In re Estate of Campbell, 46 Haw. at

508, 382 P.2d at 946 (explaining that “it is recognized in these

cases that the principal of the trust is to remain intact to

provide an income for the grandchildren as well as others” and

that wrongful depletion of corpus is a potential loss to future

takers). Further, the probate court did not directly address

whether “[t]he appearance of these parties, with their

conflicting claims, their evidence and their arguments, was of

assistance to the court in its determination of the duty of the

trustees.” See Valentin, 26 Haw. at 498.

On remand, the probate court should, consistent with

this opinion, determine whether the Cooks’ participation in the

trust litigation advanced the interests of all the beneficiaries

of the trust. A proper determination would include whether the

Cooks’ participation assisted the probate court in clarifying

the duties of the trustee in the face of an ambiguity. See

Valentin, 26 Haw. at 498.

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V. CONCLUSION

For the foregoing reasons, the ICA’s November 20,

2024, Judgment on Appeal is vacated to the extent that it

affirmed in part the probate court’s March 5, 2021 “Order

Granting Petition for Instructions Regarding Principal

Distributions and Attorneys’ Fees, and for Modification of

Trust” as to the denial of the Cooks’ request for attorneys’

fees. The ICA’s Judgment on Appeal is otherwise affirmed. This

case is remanded to the probate court for proceedings consistent

with the opinion of this court.

Thomas E. Bush /s/ Mark E. Recktenwald for petitioners/appellants

Kristin Linae Cook Kline, /s/ Sabrina S. McKenna Larry Thomas Cook, Cathy

Leann Cook Bornhorst, /s/ Todd W. Eddins Susan Kay Cook Galvin and

Jodi Charlene Cook Bosben /s/ Lisa M. Ginoza

Summer G. Shelverton and /s/ Vladimir P. Devens Caitlin M. Moon

for respondent/appellee

David Short

Rosemarie S.J. Sam,

Deirdre Marie-Iha and

Kellie K.L. Wong

for respondent/appellee

First Hawaiian Bank

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