Carmack v. Reynolds

*847 Under the terms of a spendthrift trust established by his parents, defendant Rick H. Reynolds is entitled to receive over a million dollars, all to be *848 paid out of trust principal. Reynolds filed for bankruptcy before the trust's first payment, and the bankruptcy trustee seeks to determine what interest the bankruptcy estate has in the trust. The trust is governed by California law, and as the United States Court of Appeals for the Ninth Circuit observed, the relevant statutory provisions are "opaque." ( Frealy v. Reynolds (9th Cir. 2015) 779 F.3d 1028 , 1029 ( Frealy ).) Probate Code…