Chui v. Chui - Case Brief

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Chui v. Chui

Case Number: B306918M

Court: Cal. Ct. App.

Date Filed: 2022-03-28

Case Brief – Chui v. Chui

Court: COURT OF APPEAL OF THE STATE OF CALIFORNIA
Date: 2025‑09‑03
Case Number: B306918
Disposition: The Court affirmed the trial court’s orders enforcing the May 14, 2018 oral settlement, approving the second guardian‑ad‑litem (GAL) agreement, appointing Jackson Chen as the Minors’ GAL in all related probate matters, and denying Christine Chui’s petitions to vacate the settlement, to remove Chen, and to obtain a new trial.

Holding

The court held that the trial court possessed jurisdiction to enforce the settlement agreement and to approve the second GAL agreement despite pending appeals, that the settlement and GAL agreements were valid and enforceable under Code of Civil Procedure § 664.6, and that Christine Chui, having waived her right to represent the minor beneficiaries, lacked standing to repudiate the agreements or to seek Chen’s removal as GAL.

Narrative

Lead

In a sprawling probate battle that spanned more than a decade, the California Court of Appeal upheld a complex settlement that redistributed multimillion‑dollar interests in a family trust, affirmed the appointment of a guardian‑ad‑litem for two minor beneficiaries, and rejected a series of repudiations and procedural challenges raised by the minor children’s mother. The decision clarifies the reach of a trial court’s authority to enforce settlement agreements and to approve GAL arrangements even while related appeals are pending, and it underscores the binding effect of waivers executed in the context of a settlement.

Procedural Odyssey

The dispute originated in the Los Angeles Superior Court (case BP154245) where co‑trustees Benjamin Chui and Margaret Chui filed a Probate Code § 850 petition alleging that Christine Chui and her late husband Robert had committed elder‑financial abuse against the trustor, King Wah Chui, and had misappropriated trust assets. Over the next several years, a cascade of related petitions—accounting demands, removal motions, and anti‑SLAPP challenges—filled the docket.

On May 14, 2018, the parties announced an oral settlement in open court, invoking Code of Civil Procedure § 664.6 to make the agreement enforceable. The settlement required Christine to waive all interests in Trust A, to deliver $3 million and jewelry to Benjamin’s counsel, and to relinquish any claim to the minors’ interests. In exchange, the minors would receive cash distributions and the co‑trustees would assume tax liabilities. The court recorded the settlement, asked the parties if they understood and consented, and indicated that the agreement would be subject to the minors’ GAL approval.

Subsequent to the settlement, two GAL agreements were crafted. The first, entered on August 10, 2018, was signed by guardian‑ad‑litem Jackson Chen and the co‑trustees but not by Christine. Chen later sought the trial court’s approval of that agreement; the court denied it on July 18, 2019, finding the terms not in the minors’ best interests. The parties then negotiated a second GAL agreement (January 16, 2020), which incorporated the settlement’s terms, provided substantially better economic benefits to the minors, and was signed by all parties except Christine.

Christine responded with a series of motions to vacate the settlement, to set aside the first GAL agreement, and to remove Chen as GAL. She also filed “repudiation” notices on behalf of herself and, later, on behalf of the minors. The trial court repeatedly denied these filings, ultimately granting Chen’s petition to approve the second GAL agreement, appointing Chen as the minors’ GAL in all related probate cases, and denying Christine’s removal petition.

The appellate record includes three pending appeals (B286548, B288425, B301214) concerning earlier orders. Christine, Jacqueline, and Michael appealed the March 3, 2020 consolidated rulings, the April 28, 2020 order denying a new trial, and the June 24, 2020 order approving the second GAL agreement. The Court of Appeal was asked to decide whether the trial court lacked jurisdiction because of the pending appeals and whether the settlement and GAL agreements were enforceable.

Core Issues

  1. Jurisdiction Amid Pending Appeals – Whether the trial court could lawfully enforce the settlement and approve the second GAL agreement while other appeals were pending.
  2. Validity of the Settlement and GAL Agreements – Whether the oral settlement, made under CCP § 664.6, and the subsequent GAL agreements were binding despite claims of procedural impropriety, alleged lack of meeting of the minds, and alleged unconscionability.
  3. Standing and Authority of the Parties – Whether Christine Chui, the minors’ mother, could repudiate the agreements or seek removal of Chen, given her waiver of representation rights in the settlement.
  4. Effect of Unverified Repudiations – Whether the minors’ unverified repudiation filings, made without a GAL, could defeat the approved GAL agreement.

Court’s Reasoning

1. Jurisdiction Unhindered by Pending Appeals
The appellate court held that the pending appeals did not divest the trial court of authority to rule on the settlement and GAL matters. The appeals concerned separate issues (e.g., a prior anti‑SLAPP decision and a separate accounting order) and did not stay the trial court’s inherent power to enforce a settlement that had already been entered on the record. The court cited Darling, Hall & Rae v. Kritt (1999) 75 Cal.App.4th 1148, emphasizing that a trial court may modify its “interim rulings” when new information emerges, and that such discretion remains intact despite parallel appellate proceedings.

2. Enforceability of the Settlement Under CCP § 664.6
The settlement was oral but was expressly made enforceable by the trial court’s declaration that it satisfied the statutory requirements of § 664.6: a clear, unequivocal agreement, a record of the parties’ assent, and a finding that the settlement was in the best interests of the parties. The court rejected Christine’s argument that the settlement was “unconscionable” or the product of “extrinsic fraud,” noting that the parties had ample opportunity to object, that the settlement was recorded before the court, and that the subsequent GAL agreements did not materially alter the settlement’s terms.

3. Standing and Waiver
Crucially, the settlement itself contained a waiver provision stating that the minors’ claims “can only be brought by their guardian ad litem, Chen.” By signing the settlement, Christine expressly relinquished any right to represent the minors in the underlying trust litigation. The appellate court held that this waiver barred her from later seeking Chen’s removal or from filing repudiations on the minors’ behalf. The court also found that Christine lacked standing to challenge the second GAL agreement because she was not a party to that agreement and had previously waived her authority to act for the minors.

4. Invalidity of Unverified Repudiations
The minors’ repudiation notices were filed without verification and without the involvement of their GAL. The court stressed that a GAL’s petition for approval is a non‑adversarial proceeding between the court and the officer; any objections must be made through the GAL, not by the minors independently. Consequently, the repudiations were deemed “improper and irrelevant” and could not defeat the approved GAL agreement.

5. Substantive Merits of the Second GAL Agreement
The appellate court affirmed the trial court’s finding that the second GAL agreement provided “substantially better economic terms” for the minors than the first, including cash distributions totaling roughly $1.48 million and the elimination of the minors’ future tax liabilities. The court rejected speculative arguments about hypothetical trial outcomes, emphasizing that the agreement’s concrete benefits rendered it a “good deal” for the minors under the standards governing GAL approvals.

Outcome

The Court of Appeal affirmed the trial court’s orders:

  • Enforcement of the May 14, 2018 settlement;
  • Approval of the January 16, 2020 second GAL agreement;
  • Appointment of Jackson Chen as guardian‑ad‑litem for the minors in all related probate matters;
  • Denial of Christine Chui’s petitions to vacate the settlement, to remove Chen, and to obtain a new trial; and
  • Rejection of the minors’ unverified repudiations.

Closing Analysis

Chui v. Chui delivers a decisive message to California probate practitioners: once parties have entered a settlement that satisfies CCP § 664.6, the court may enforce it and any ancillary GAL agreements even amid a thicket of related appeals. The decision underscores the binding effect of waiver provisions embedded in settlement instruments, particularly where a party relinquishes the right to represent a minor beneficiary.

The ruling also clarifies the limited role of a minor’s unverified repudiation—without a GAL’s participation, such filings are ineffective. Practitioners should therefore ensure that any challenge to a settlement affecting a minor is routed through the appointed GAL, and that waivers are drafted with precision to preclude later standing disputes.

Unresolved questions linger regarding the scope of a GAL’s authority when multiple related probate cases are consolidated. While the appellate court treated the GAL’s appointment across cases as a “curative” measure for administrative oversight, future litigants may test the limits of such extensions, especially where a guardian’s conflict of interest is alleged. Additionally, the decision leaves open the question of how courts will handle settlements that involve substantial future tax liabilities and complex property exchanges—issues that may surface as California’s probate landscape continues to evolve.

For attorneys navigating multi‑party trust disputes, Chui serves as a roadmap: secure clear, court‑recorded settlements; embed explicit waiver language; involve the GAL early; and anticipate that once a settlement is ratified, the court’s hands are largely tied, even in the face of lingering appeals.

Referenced Statutes and Doctrines

  • Probate Code §§ 850, 850.2, 259 – Elder abuse and fiduciary duty claims.
  • Civil Code § 1542 – Waiver of unknown claims (referenced in settlement waivers).
  • Code of Civil Procedure §§ 664.6, 631.8, 425.16 – Enforcement of settlement agreements; nonsuit/judgment motions; anti‑SLAPP statute.
  • Probate Code § 850.2 – Standards for guardian‑ad‑litem approvals.
  • Doctrine of Waiver and Release – Parties’ contractual relinquishment of rights.
  • Guardian‑Ad‑Litem Authority – Non‑adversarial nature of GAL petitions; standing limited to the minor and the GAL.
  • Interim Rulings Doctrine – Trial courts may modify prior interim orders upon new evidence (Darling, Hall & Rae v. Kritt, 75 Cal.App.4th 1148).