Erickson v. Bank of California, N.A.

The trustee in bankruptcy for George Leslie Schafer appealed a summary judgment of the trial court dismissing his complaint, which attempted to reach the bankrupt's interest in the assets of a spendthrift trust. The cotrustees of the trust refused to submit to an accounting of Schafer's interest in the trust. The Court of Appeals set aside the trial court's summary judgment dismissal and remanded for a factual determination of whether the withholding of payment to the creditors was an abuse of the cotrustees' discretion in denying payments for "necessities". In doing so, the Court of Appeals…