J. Steven Tikalsky v. Susan Friedman

*764¶1 In a vigorous dispute over the distribution of Donald and Betty Lou Tikalsky's estate, J. Steven Tikalsky sued his sister, Terry Stevens, to obtain part of the inheritance she received from their parents. His Complaint contains a count labeled "constructive trust," which he deployed against his sister as a cause of action. Terry Stevens asks us whether a "constructive trust" may play that role, and whether it may be used against those who have engaged *765in no inequitable behavior. We hold that a constructive trust is a remedy, not a cause of action. We also hold that, under the proper…