Dawes v. Rich
Court of Appeal of California
60 Cal. App. 4th 24 (1997)
Tenants (plaintiffs) obtained judgments against David Dawes for rent-related claims; before those judgments, David and his wife Dorothy had transferred their community property into inter vivos trusts administered by their sons (defendants) as trustees, and Dorothy died in 1990 with her property passing through the trusts without probate. The tenants later sought writs of execution against the trusts to satisfy David's judgment debts, the trustees petitioned to have the trusts declared immune, and the trial and probate courts found the tenants' claims untimely; the tenants appealed the consolidated rulings.
Whether, pursuant to state law, the liability of a deceased spouse's estate for community debts is subject to a one-year statute of limitations.