In re Estate of Myers

Karen died owning several pay-on-death (POD) assets, including a checking account, certificate of deposit, and annuity payable directly to her daughters upon her death; after her husband Howard filed for a statutory elective share of her estate and assigned that right to satisfy a judgment against him, the assignees sought a ruling on whether the POD assets should count toward Howard's elective share, and the probate court, relying on prior precedent finding that a decedent's retained control over trust assets brought them within the elective share, held the POD assets should be included since Karen retained complete control over them before death.